Online bond platforms may offer overseas-regulated products and tax-specific bonds subject to disclosures, compliance safeguards and revised complianc...
Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Revision u/s 263 - nature of expenditure - There is no averment in the reply of the assessee that the amount of share application money was received for ‘brand building’ of the assessee company. Again turning to the core issue that the share application money in nothing but a ‘capital receipt’ and its return will not change its character. Even otherwise the assessee has not incurred any other amount except the exchange rate difference, which in our considered view is nothing but a ‘capital expenses’. - order passed by AO is not sustainable in law and hence not only erroneous but in so far as prejudicial to the interest of the Revenue. - AT
Revision u/s 263 - nature of expenditure - There is no averment in the reply of the assessee that the amount of share application money was received for ‘brand building’ of the assessee company. Again turning to the core issue that the share application money in nothing but a ‘capital receipt’ and its return will not change its character. Even otherwise the assessee has not incurred any other amount except the exchange rate difference, which in our considered view is nothing but a ‘capital expenses’. - order passed by AO is not sustainable in law and hence not only erroneous but in so far as prejudicial to the interest of the Revenue. - AT
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