Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Pre-existing operational debt disputes require genuine evidence, while undirected running-account payments may be appropriated on a first-in-first-out...
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Reopening of assessment u/s 147 - having business connection as well as Permanent Establishment [PE] in India - evidence being sought to be used for initiating fresh enquiry against the assessee does not even pertain to the Assessment Year under consideration. In our considered opinion, whether a PE exists or not is a fact specific issue and is to be decided on year on year basis. - no new tangible material has been brought by the Assessing Officer to justify the reopening - AT
Reopening of assessment u/s 147 - having business connection as well as Permanent Establishment [PE] in India - evidence being sought to be used for initiating fresh enquiry against the assessee does not even pertain to the Assessment Year under consideration. In our considered opinion, whether a PE exists or not is a fact specific issue and is to be decided on year on year basis. - no new tangible material has been brought by the Assessing Officer to justify the reopening - AT
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