Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Validity of reopening of the case u/s. 147 - Reasons to believe - addition as unexplained cash credit u/s. 68 against sale of shares / investments along with share premium - The ITAT found that the reasons recorded for reopening were vague and lacked specificity, and the approval obtained was mechanical. Additionally, it concluded that the transactions in question were sales of shares held as investments, supported by evidence provided by the appellant. Consequently, the ITAT ruled in favor of the appellant, allowing the appeals and rejecting the additions made by the AO.
Validity of reopening of the case u/s. 147 - Reasons to believe - addition as unexplained cash credit u/s. 68 against sale of shares / investments along with share premium - The ITAT found that the reasons recorded for reopening were vague and lacked specificity, and the approval obtained was mechanical. Additionally, it concluded that the transactions in question were sales of shares held as investments, supported by evidence provided by the appellant. Consequently, the ITAT ruled in favor of the appellant, allowing the appeals and rejecting the additions made by the AO.
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