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...
Rectification u/s 154 - Chargeability of interest u/s 234B and 234C - income returned u/s 115JB - The return was assessed under section 143(3) of the Act, and no interest was charged under sections 234B and 234C as per the prevailing law. - Subsequently, a search and seizure operation was conducted, leading to proceedings under section 153A. The CIT(A) deleted all additions made in the assessment order under section 153A. - However, while giving appeal effect to the CIT(A)'s order, the Assessing Officer introduced a new issue of charging interest under sections 234B and 234C, which was not part of the original assessment or appeal. - The ITAT held that the Assessing Officer exceeded his jurisdiction by introducing a new issue of charging interest under sections 234B and 234C during appeal effect.
Rectification u/s 154 - Chargeability of interest u/s 234B and 234C - income returned u/s 115JB - The return was assessed under section 143(3) of the Act, and no interest was charged under sections 234B and 234C as per the prevailing law. - Subsequently, a search and seizure operation was conducted, leading to proceedings under section 153A. The CIT(A) deleted all additions made in the assessment order under section 153A. - However, while giving appeal effect to the CIT(A)'s order, the Assessing Officer introduced a new issue of charging interest under sections 234B and 234C, which was not part of the original assessment or appeal. - The ITAT held that the Assessing Officer exceeded his jurisdiction by introducing a new issue of charging interest under sections 234B and 234C during appeal effect.
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