Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Set off of brought forward loss against Long Term Capital Gain (LTCG) - AO was of the view that since the LTCL no longer exist in books of account, it cannot be set off consequent to the scheme of arrangement - It has not been brought out on record that by reason of the restructuring the books and the order of the Hon’ble Kerala High Court, the assessee is precluded from utilizing the carryforward LTCL against set off of LTCG in future years as contemplated by section 74 of the Act. - AT
Set off of brought forward loss against Long Term Capital Gain (LTCG) - AO was of the view that since the LTCL no longer exist in books of account, it cannot be set off consequent to the scheme of arrangement - It has not been brought out on record that by reason of the restructuring the books and the order of the Hon’ble Kerala High Court, the assessee is precluded from utilizing the carryforward LTCL against set off of LTCG in future years as contemplated by section 74 of the Act. - AT
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