Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
LTCG - year of assessment - The Tribunal noted discrepancies in the year of taxability claims, stating that the original Joint Development Agreement (JDA) underwent substantial modification, which affected the final assessment year. Since the assessee offered the gains for tax in AY 2016-17, the Tribunal found no grounds to shift the taxability year to AY 2013-14 or AY 2015-16. - Regarding the computation of LTCG, the ITAT upheld the assessing officer’s decision to consider only the proportionate cost of land transferred and noted that the assessee could not substantiate the claimed costs of the building constructed in 1983-84. The Tribunal directed a recalibration of the fair market value of the building as of 01-04-1981, rejecting the depreciation applied by the assessing officer.
LTCG - year of assessment - The Tribunal noted discrepancies in the year of taxability claims, stating that the original Joint Development Agreement (JDA) underwent substantial modification, which affected the final assessment year. Since the assessee offered the gains for tax in AY 2016-17, the Tribunal found no grounds to shift the taxability year to AY 2013-14 or AY 2015-16. - Regarding the computation of LTCG, the ITAT upheld the assessing officer’s decision to consider only the proportionate cost of land transferred and noted that the assessee could not substantiate the claimed costs of the building constructed in 1983-84. The Tribunal directed a recalibration of the fair market value of the building as of 01-04-1981, rejecting the depreciation applied by the assessing officer.
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