Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Filling of Modified return after amalgamation - Effect of order of tribunal or court in respect of business reorganisation u/s 170A - The High Court observed that Section 170A of the Income Tax Act mandates that any assessment after a business reorganization should be based on the modified return. Since the scheme of amalgamation became effective from 01.04.2020, the petitioner's consolidated return after amalgamation should have been the basis for assessment. - Consequently, the matter remanded back to AO to make a reassessment on the basis of such consolidated return of income.
Filling of Modified return after amalgamation - Effect of order of tribunal or court in respect of business reorganisation u/s 170A - The High Court observed that Section 170A of the Income Tax Act mandates that any assessment after a business reorganization should be based on the modified return. Since the scheme of amalgamation became effective from 01.04.2020, the petitioner's consolidated return after amalgamation should have been the basis for assessment. - Consequently, the matter remanded back to AO to make a reassessment on the basis of such consolidated return of income.
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