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...
The ITAT Ahmedabad held that a best judgment assessment u/s 144 without issuing notice u/s 143(2) is invalid if the assessee has filed a return and responded to AO's notice. Courts emphasize Section 144 is for non-compliance cases. Assessee provided details of cash deposits, supported by affidavits from relatives. Deposits were found to be from maturity proceeds, not unexplained money u/s 69A. Addition in brother's hands linked to joint account. CIT(A) erred in upholding half of assessment u/s 69A. Affidavits, if credible, can explain cash source. Lack of concrete reasons to reject explanations. Entire u/s 69A addition deleted, penalty proceedings u/s 271AAC(1) & 271F dropped. Assessee's appeal allowed.
The ITAT Ahmedabad held that a best judgment assessment u/s 144 without issuing notice u/s 143(2) is invalid if the assessee has filed a return and responded to AO's notice. Courts emphasize Section 144 is for non-compliance cases. Assessee provided details of cash deposits, supported by affidavits from relatives. Deposits were found to be from maturity proceeds, not unexplained money u/s 69A. Addition in brother's hands linked to joint account. CIT(A) erred in upholding half of assessment u/s 69A. Affidavits, if credible, can explain cash source. Lack of concrete reasons to reject explanations. Entire u/s 69A addition deleted, penalty proceedings u/s 271AAC(1) & 271F dropped. Assessee's appeal allowed.
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