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...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Revision u/s 263 - non application of mind by AO on search figures of income - PCIT has not brought any material to justify the alleged income of ₹ 210 crores. Thus, we note that allegation made by the ld PCIT is based merely on suspicion and conjecture. A mere observation that no proper details have been obtained, cannot be sufficient to come to a conclusion that the assessing officer did not make proper and adequate inquiries which he ought to have made in the given facts and circumstances of this case. - AT
Revision u/s 263 - non application of mind by AO on search figures of income - PCIT has not brought any material to justify the alleged income of ₹ 210 crores. Thus, we note that allegation made by the ld PCIT is based merely on suspicion and conjecture. A mere observation that no proper details have been obtained, cannot be sufficient to come to a conclusion that the assessing officer did not make proper and adequate inquiries which he ought to have made in the given facts and circumstances of this case. - AT
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