Judicial discipline requires consistent reassessment treatment where identical facts were decided for the same taxpayer in the preceding assessment ye...
Agreement-date stamp valuation requires the same registered property, fixed consideration, and qualifying payment; an unrelated prior booking cannot a...
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Income deemed to accrue or arise in India - Royalty Income - AO had treated an amount as royalty income of the assessee during the year purely based on the amount shown in Form 26AS, however, CIT (Appeals) has restricted the addition purely based on the four invoices raised by the assessee. When the admitted factual position is that the assessee has not even received any amount against those four invoices, in our view, the royalty income cannot be added on notional basis. - AT
Income deemed to accrue or arise in India - Royalty Income - AO had treated an amount as royalty income of the assessee during the year purely based on the amount shown in Form 26AS, however, CIT (Appeals) has restricted the addition purely based on the four invoices raised by the assessee. When the admitted factual position is that the assessee has not even received any amount against those four invoices, in our view, the royalty income cannot be added on notional basis. - AT
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