Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Jurisdiction of AO to issue notice u/s 143(2) - notice u/s 143(2) was issued by one AO and the assessment has been completed by another AO - The provisions of sub-section (4) of section 127 will be applicable only when there is an order under section 127 of the Act. Since the Department was not able to show any order passed under section 127 of the Act, this argument of the ld. Counsel for the assessee is also accepted. - AT
Jurisdiction of AO to issue notice u/s 143(2) - notice u/s 143(2) was issued by one AO and the assessment has been completed by another AO - The provisions of sub-section (4) of section 127 will be applicable only when there is an order under section 127 of the Act. Since the Department was not able to show any order passed under section 127 of the Act, this argument of the ld. Counsel for the assessee is also accepted. - AT
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