Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The ITAT Mumbai ruled on the reopening of assessment u/s 147 beyond four years and disallowance of deduction u/s 10(38) for alleged bogus LTCG. The Tribunal held that as the Assessee had fully disclosed material facts, the reopening was unjustified. Regarding addition u/s 68 for shares purchased off-market and later sold online, the Tribunal found no evidence of wrongdoing by the Assessee or the broker. The Assessee provided relevant documents and the AO did not question their authenticity. Citing a precedent, the Tribunal allowed the deduction u/s 10(38) as the shares were legitimately traded on the stock exchange. The decision favored the Assessee.
The ITAT Mumbai ruled on the reopening of assessment u/s 147 beyond four years and disallowance of deduction u/s 10(38) for alleged bogus LTCG. The Tribunal held that as the Assessee had fully disclosed material facts, the reopening was unjustified. Regarding addition u/s 68 for shares purchased off-market and later sold online, the Tribunal found no evidence of wrongdoing by the Assessee or the broker. The Assessee provided relevant documents and the AO did not question their authenticity. Citing a precedent, the Tribunal allowed the deduction u/s 10(38) as the shares were legitimately traded on the stock exchange. The decision favored the Assessee.
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