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...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Assessment made u/s 144 r.w.s. 142(1) OR 153C - The Tribunal held that the assessment made u/s 144 r.w.s. 142(1) for A.Y. 2012-13, based on the satisfaction recorded on 18.11.2013 (A.Y. 2014-15), should have been conducted u/s 153C of the Income Tax Act. The Tribunal referenced the judgments of the Hon’ble Delhi High Court and the Hon’ble Supreme Court, stating that the satisfaction note must explicitly indicate that the seized documents belong to the assessee. The Tribunal found that the assessments made were outside the scope of Section 153C, and hence, the assessment u/s 144 r.w.s. 142(1) was void ab initio.
Assessment made u/s 144 r.w.s. 142(1) OR 153C - The Tribunal held that the assessment made u/s 144 r.w.s. 142(1) for A.Y. 2012-13, based on the satisfaction recorded on 18.11.2013 (A.Y. 2014-15), should have been conducted u/s 153C of the Income Tax Act. The Tribunal referenced the judgments of the Hon’ble Delhi High Court and the Hon’ble Supreme Court, stating that the satisfaction note must explicitly indicate that the seized documents belong to the assessee. The Tribunal found that the assessments made were outside the scope of Section 153C, and hence, the assessment u/s 144 r.w.s. 142(1) was void ab initio.
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