Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
TP Adjustment - related parties / associated enterprise or not - Re-computation of arm's length price of shares sold by the assessee - Admittedly, in the instant case Relay BV holds controlling stake in USL of more than 26% i.e. 26, 37% on 28.11.2013 i.e. during the relevant previous year. Therefore in light of the clear provisions of Section 92A(2) of the Act, which uses the expression "if at any time during the previous year" we find no merit in the contention of the learned Sr. Counsel. - AT
TP Adjustment - related parties / associated enterprise or not - Re-computation of arm's length price of shares sold by the assessee - Admittedly, in the instant case Relay BV holds controlling stake in USL of more than 26% i.e. 26, 37% on 28.11.2013 i.e. during the relevant previous year. Therefore in light of the clear provisions of Section 92A(2) of the Act, which uses the expression "if at any time during the previous year" we find no merit in the contention of the learned Sr. Counsel. - AT
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