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...
In a charitable institution's assessment, the Tribunal held that application of current-year income and accumulated funds, as separately disclosed in the return and Form 10B and verified in scrutiny, could not be disallowed on a supposed mismatch; once the Assessing Officer recorded that there was no difference between the two, the earlier prima facie adjustment under section 143(1) had no surviving basis and the claim was allowed in full. It also held that no fresh claim was being raised on appeal, so Goetze (India) was inapplicable. The final computation wrongly duplicated the same income components, inflating the taxable base; tax under section 115BBI and interest under sections 234B and 234C were consequential and had to be recomputed. The appeal was allowed.
In a charitable institution's assessment, the Tribunal held that application of current-year income and accumulated funds, as separately disclosed in the return and Form 10B and verified in scrutiny, could not be disallowed on a supposed mismatch; once the Assessing Officer recorded that there was no difference between the two, the earlier prima facie adjustment under section 143(1) had no surviving basis and the claim was allowed in full. It also held that no fresh claim was being raised on appeal, so Goetze (India) was inapplicable. The final computation wrongly duplicated the same income components, inflating the taxable base; tax under section 115BBI and interest under sections 234B and 234C were consequential and had to be recomputed. The appeal was allowed.
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