Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Revision u/s 263 - Disallowance of STCG - FMV determination of shares - The Appellate Tribunal (AT) scrutinized the fair market value and share valuation process, concluding that the appellant failed to substantiate their claims adequately. They found discrepancies in the valuation and affirmed the PCIT's decision to reject the appellant's arguments. The AT affirmed the PCIT's characterization of the transactions as structured and not at arm's length. They concluded that the assessment order was prejudicial to the interest of the Revenue and upheld the PCIT's decision to set it aside.
Revision u/s 263 - Disallowance of STCG - FMV determination of shares - The Appellate Tribunal (AT) scrutinized the fair market value and share valuation process, concluding that the appellant failed to substantiate their claims adequately. They found discrepancies in the valuation and affirmed the PCIT's decision to reject the appellant's arguments. The AT affirmed the PCIT's characterization of the transactions as structured and not at arm's length. They concluded that the assessment order was prejudicial to the interest of the Revenue and upheld the PCIT's decision to set it aside.
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