Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Exemption u/s 10(23C) (iv) - Charitable activity u/s 2(15) or not? - The petitioner, an institution promoting trade, sought exemption under Section 10(23C)(iv) of the Income Tax Act. The Revenue rejected the claim, citing the proviso to Section 2(15) of the Act. The petitioner challenged this decision, relying on a subsequent ITAT judgment. The court upheld the retrospective application of judicial decisions and emphasized the binding nature of appellate authority's orders on revenue officers. It quashed the impugned order and remanded the matter for reconsideration in light of the ITAT's decision.
Exemption u/s 10(23C) (iv) - Charitable activity u/s 2(15) or not? - The petitioner, an institution promoting trade, sought exemption under Section 10(23C)(iv) of the Income Tax Act. The Revenue rejected the claim, citing the proviso to Section 2(15) of the Act. The petitioner challenged this decision, relying on a subsequent ITAT judgment. The court upheld the retrospective application of judicial decisions and emphasized the binding nature of appellate authority's orders on revenue officers. It quashed the impugned order and remanded the matter for reconsideration in light of the ITAT's decision.
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