Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Assessment u/s 153C - Relevant Date - date on which the AO of the person other than the one searched assumes the possession of the seized assets - The Tribunal's decision emphasized the principle that for initiating proceedings u/s 153C, it is essential to follow the statutory timelines and conditions prescribed under the Income Tax Act. The Tribunal relied on judgments from the Hon'ble High Court and the Supreme Court to conclude that the assessments made for the Assessment Years 2006-07 and 2007-08, based on a satisfaction note recorded, were outside the scope of Section 153C. This led to the conclusion that these assessments were void ab initio, along with the assessment for A.Y. 2012-13. - AT
Assessment u/s 153C - Relevant Date - date on which the AO of the person other than the one searched assumes the possession of the seized assets - The Tribunal's decision emphasized the principle that for initiating proceedings u/s 153C, it is essential to follow the statutory timelines and conditions prescribed under the Income Tax Act. The Tribunal relied on judgments from the Hon'ble High Court and the Supreme Court to conclude that the assessments made for the Assessment Years 2006-07 and 2007-08, based on a satisfaction note recorded, were outside the scope of Section 153C. This led to the conclusion that these assessments were void ab initio, along with the assessment for A.Y. 2012-13. - AT
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