Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Reopening of assessment u/s 147 - AO has proceeded to reopen the assessment on the basis of wrong appreciation of facts by mentioning that the assessment is proposed to be made for the first time whereas the facts stood otherwise - Approval has been given in a mechanical manner without appreciating the facts properly and there is complete non-application of mind by the superior authorities. - reassessment proceedings have to be quashed - AT
Reopening of assessment u/s 147 - AO has proceeded to reopen the assessment on the basis of wrong appreciation of facts by mentioning that the assessment is proposed to be made for the first time whereas the facts stood otherwise - Approval has been given in a mechanical manner without appreciating the facts properly and there is complete non-application of mind by the superior authorities. - reassessment proceedings have to be quashed - AT
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