Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Goodwill write-off already added back in computing taxable income should not be added again in assessment; an ambiguous rectification that potentially disallows goodwill beyond withdrawal of consequential depreciation cannot prejudice the assessee. The further goodwill disallowance was deleted, while the depreciation disallowance was sustained on the assessee's concession. A claim for set-off of brought-forward business losses requires verification of its quantum and eligibility from earlier-year records where it has not been adjudicated. That claim was remitted to the AO for verification and lawful set-off after reasonable opportunity. The appeal was partly allowed for statistical purposes.
Goodwill write-off already added back in computing taxable income should not be added again in assessment; an ambiguous rectification that potentially disallows goodwill beyond withdrawal of consequential depreciation cannot prejudice the assessee. The further goodwill disallowance was deleted, while the depreciation disallowance was sustained on the assessee's concession. A claim for set-off of brought-forward business losses requires verification of its quantum and eligibility from earlier-year records where it has not been adjudicated. That claim was remitted to the AO for verification and lawful set-off after reasonable opportunity. The appeal was partly allowed for statistical purposes.
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