Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Indexation on a capital asset received in amalgamation was held to run from FY 2008-09 because the township had already been constructed and let out by the amalgamating company, with rental income taxed from that year; the tax-neutral transfer under the scheme did not shift the holding period to the later amalgamation order or occupancy certificate. The Tribunal also upheld the claimed short-term capital loss on sale of AIF units to a subsidiary, finding both acquisition and sale valuations followed the NAV method, the fall in value was explained by decline in underlying investments, and a related-party sale is not a colourable device without evidence of tax avoidance. Both revenue appeals were dismissed.
Indexation on a capital asset received in amalgamation was held to run from FY 2008-09 because the township had already been constructed and let out by the amalgamating company, with rental income taxed from that year; the tax-neutral transfer under the scheme did not shift the holding period to the later amalgamation order or occupancy certificate. The Tribunal also upheld the claimed short-term capital loss on sale of AIF units to a subsidiary, finding both acquisition and sale valuations followed the NAV method, the fall in value was explained by decline in underlying investments, and a related-party sale is not a colourable device without evidence of tax avoidance. Both revenue appeals were dismissed.
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