Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Transfer pricing of intra-group services required fresh examination because CUP could not be applied at nil without uncontrolled comparable transactions, and the TPO had to consider the evidence and additional evidence on actual receipt and nature of services; the impugned adjustment was therefore set aside and remanded. On unabsorbed depreciation, the Tribunal held that depreciation relating to earlier years, not absorbed by financial year 2002-03, merged with subsequent-year depreciation and was not subject to the earlier eight-year restriction after the amendment to section 32(2); the assessee's claim for carry forward and set-off beyond eight years was allowed and the Revenue's challenge was rejected.
Transfer pricing of intra-group services required fresh examination because CUP could not be applied at nil without uncontrolled comparable transactions, and the TPO had to consider the evidence and additional evidence on actual receipt and nature of services; the impugned adjustment was therefore set aside and remanded. On unabsorbed depreciation, the Tribunal held that depreciation relating to earlier years, not absorbed by financial year 2002-03, merged with subsequent-year depreciation and was not subject to the earlier eight-year restriction after the amendment to section 32(2); the assessee's claim for carry forward and set-off beyond eight years was allowed and the Revenue's challenge was rejected.
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