Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Diversion of income by overriding title arose where a collaboration agreement, banking records, ledger accounts and supporting material established the collaborator's entitlement to a share of flat-sale proceeds. That share did not accrue as the assessee's income because the agreement imposed an overriding obligation; procedural non-compliance, stamp-paper objections, lack of witnesses or doubts about expertise did not establish a fictitious income-diversion device. The resulting addition was deleted. Land acquisition cost could not be disallowed on the basis that it was absent from the books, since the books recorded the land and the purchase deed substantiated acquisition. The unexplained-source inference and related disallowance were deleted.
Diversion of income by overriding title arose where a collaboration agreement, banking records, ledger accounts and supporting material established the collaborator's entitlement to a share of flat-sale proceeds. That share did not accrue as the assessee's income because the agreement imposed an overriding obligation; procedural non-compliance, stamp-paper objections, lack of witnesses or doubts about expertise did not establish a fictitious income-diversion device. The resulting addition was deleted. Land acquisition cost could not be disallowed on the basis that it was absent from the books, since the books recorded the land and the purchase deed substantiated acquisition. The unexplained-source inference and related disallowance were deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
