Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
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Taxability of unutilized accumulated funds u/s 11(2) as income u/s 11(3) - The CIT(A) upheld the Assessing Officer's decision, which was based on a Section 263 order from the DIT(E), regarding the taxability of these funds. However, the Tribunal, guided by a High Court order, restored the appeal to the CIT(A) for reconsideration, specifically within the framework of Sections 11(2) and 11(3) of the Act, after giving the assessee a fair opportunity to be heard. - AT
Taxability of unutilized accumulated funds u/s 11(2) as income u/s 11(3) - The CIT(A) upheld the Assessing Officer's decision, which was based on a Section 263 order from the DIT(E), regarding the taxability of these funds. However, the Tribunal, guided by a High Court order, restored the appeal to the CIT(A) for reconsideration, specifically within the framework of Sections 11(2) and 11(3) of the Act, after giving the assessee a fair opportunity to be heard. - AT
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