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Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Adjustment made u/s 115JB in Rectification order u/s 154 - Debatable issue - addition of surrendered income by the assessee was included in the book profit of the assessee as per Section 115JB - The Revenue argued that the disclosed income should be considered as part of the book profit for tax calculation purposes. However, the respondent contended that the inclusion of this income required extensive debate and was not supported by incriminating material found during the survey. The Tribunal agreed with the respondent, concluding that the Assessing Officer's action under Section 154 was unwarranted due to the debatable nature of the issue. Consequently, the Tribunal dismissed the appeal of the Revenue.
Adjustment made u/s 115JB in Rectification order u/s 154 - Debatable issue - addition of surrendered income by the assessee was included in the book profit of the assessee as per Section 115JB - The Revenue argued that the disclosed income should be considered as part of the book profit for tax calculation purposes. However, the respondent contended that the inclusion of this income required extensive debate and was not supported by incriminating material found during the survey. The Tribunal agreed with the respondent, concluding that the Assessing Officer's action under Section 154 was unwarranted due to the debatable nature of the issue. Consequently, the Tribunal dismissed the appeal of the Revenue.
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