Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Levy of interest u/s 234A and 234B - defaults in furnishing return of income - The Case and situation pertains to situations where the original assessment is set aside during appellate proceedings for fresh assessment. In such cases, there is contention between the Revenue and the assessee regarding whether the subsequent assessment should be considered the regular assessment or if it is still the first assessment. - Since the existing precedents failed to address the changed legal scenario and legislative amendments, the Tribunal deemed it necessary to reexamine the computation of interest under sections 234A and 234B. - Therefore, the Tribunal decided to remand the issue back to the ld. CIT(A) for fresh consideration, allowing both parties to present their arguments and considering all relevant decisions.
Levy of interest u/s 234A and 234B - defaults in furnishing return of income - The Case and situation pertains to situations where the original assessment is set aside during appellate proceedings for fresh assessment. In such cases, there is contention between the Revenue and the assessee regarding whether the subsequent assessment should be considered the regular assessment or if it is still the first assessment. - Since the existing precedents failed to address the changed legal scenario and legislative amendments, the Tribunal deemed it necessary to reexamine the computation of interest under sections 234A and 234B. - Therefore, the Tribunal decided to remand the issue back to the ld. CIT(A) for fresh consideration, allowing both parties to present their arguments and considering all relevant decisions.
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