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...
Enhancement of assessment - Power of CIT(A) u/s 251(2) - addition u/s 56(2)(vii) - The appellant had received Rs. 25,00,000 as a security deposit from a developer, the amount was subsequently repaid - Providing / granting the appellant a reasonable opportunity to present their case against the enhancement - The Tribunal deemed this non-compliance as an irregularity rather than an illegality. However, the Tribunal decided to review the addition made under section 56(2)(vii) of the Act. It was determined that since the deposit received by the appellant was not without consideration, being related to a development agreement, the addition was not sustainable. Therefore, the appeal was allowed, and the impugned additions were directed to be deleted.
Enhancement of assessment - Power of CIT(A) u/s 251(2) - addition u/s 56(2)(vii) - The appellant had received Rs. 25,00,000 as a security deposit from a developer, the amount was subsequently repaid - Providing / granting the appellant a reasonable opportunity to present their case against the enhancement - The Tribunal deemed this non-compliance as an irregularity rather than an illegality. However, the Tribunal decided to review the addition made under section 56(2)(vii) of the Act. It was determined that since the deposit received by the appellant was not without consideration, being related to a development agreement, the addition was not sustainable. Therefore, the appeal was allowed, and the impugned additions were directed to be deleted.
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