Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Unabated assessments under section 153A permit additions for escaped income only where incriminating material is found during the search. In the absence of such assessee-specific material, the additions were deleted. Reassessment initiated on recorded reasons that misstated the assessee's investment and conflicted with the investee company's financial statements reflected non-application of mind; the reassessment was therefore void from inception and quashed, with merits left open. Penalty under section 271(1)(c) could not survive once its sole supporting quantum addition had been deleted, and was consequently deleted.
Unabated assessments under section 153A permit additions for escaped income only where incriminating material is found during the search. In the absence of such assessee-specific material, the additions were deleted. Reassessment initiated on recorded reasons that misstated the assessee's investment and conflicted with the investee company's financial statements reflected non-application of mind; the reassessment was therefore void from inception and quashed, with merits left open. Penalty under section 271(1)(c) could not survive once its sole supporting quantum addition had been deleted, and was consequently deleted.
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