Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Section 53A of the Transfer of Property Act did not confer ownership for depreciation where there was no written and registered transfer instrument, so the assessee could not treat the properties as firm assets or claim depreciation on that basis. The assessment was also not vitiated by natural justice grounds because the show-cause process and repeated notices already covered the relevant factual basis, and the shift from unexplained investment to unexplained credit was treated as a consequence of the same inquiry. Having rejected the jurisdictional and procedural objections, the Court declined to examine the merits of the unexplained credit dispute in writ jurisdiction and relegated the assessee to the statutory appellate remedy.
Section 53A of the Transfer of Property Act did not confer ownership for depreciation where there was no written and registered transfer instrument, so the assessee could not treat the properties as firm assets or claim depreciation on that basis. The assessment was also not vitiated by natural justice grounds because the show-cause process and repeated notices already covered the relevant factual basis, and the shift from unexplained investment to unexplained credit was treated as a consequence of the same inquiry. Having rejected the jurisdictional and procedural objections, the Court declined to examine the merits of the unexplained credit dispute in writ jurisdiction and relegated the assessee to the statutory appellate remedy.
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