Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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Under the post-1.4.2021 reassessment scheme, notice under section 148 can be issued where the Assessing Officer has material indicating escapement of income, and the sufficiency of incriminating material is tested in reassessment, not at the notice stage; the reopening was therefore upheld. The Tribunal also held that section 170 governs successor liability on amalgamation and that absence of pending proceedings on the amalgamation date did not invalidate action against the successor. On merits, additions treating sale proceeds of earlier-year investments as unexplained cash credit, and related commission for alleged accommodation entries, were deleted because the transactions were supported by banking records, the investments had earlier been accepted, and reliance on third-party statements without cross-examination violated natural justice.
Under the post-1.4.2021 reassessment scheme, notice under section 148 can be issued where the Assessing Officer has material indicating escapement of income, and the sufficiency of incriminating material is tested in reassessment, not at the notice stage; the reopening was therefore upheld. The Tribunal also held that section 170 governs successor liability on amalgamation and that absence of pending proceedings on the amalgamation date did not invalidate action against the successor. On merits, additions treating sale proceeds of earlier-year investments as unexplained cash credit, and related commission for alleged accommodation entries, were deleted because the transactions were supported by banking records, the investments had earlier been accepted, and reliance on third-party statements without cross-examination violated natural justice.
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