Separate speaking orders on reopening objections are mandatory; deciding them within reassessment invalidates jurisdiction and precludes revival of st...
Compulsorily convertible debentures remain debt before conversion, preventing transfer-pricing and interest-deduction disallowances on the stated fact...
Stock-in-trade transfer taxability follows possession and consideration, not later conveyance registration, limiting deemed-value provisions to the ac...
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
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
