Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
The ITAT, an Appellate Tribunal, addressed the validity of reopening assessment u/s 147 and addition u/s 68. The AO had sufficient material to believe the assessee introduced unaccounted income as bogus share capital, leading to income escapement. The notice u/s 147 was upheld as valid. The assessee failed to prove creditworthiness of share applicant or transaction genuineness. AO's addition u/s 68 was deemed justified, concluding the assessee channeled its own funds through investor companies. The assessee engaged in dubious activities, introducing unaccounted money through questionable transactions. The CIT(A)'s order was upheld, ruling against the assessee.
The ITAT, an Appellate Tribunal, addressed the validity of reopening assessment u/s 147 and addition u/s 68. The AO had sufficient material to believe the assessee introduced unaccounted income as bogus share capital, leading to income escapement. The notice u/s 147 was upheld as valid. The assessee failed to prove creditworthiness of share applicant or transaction genuineness. AO's addition u/s 68 was deemed justified, concluding the assessee channeled its own funds through investor companies. The assessee engaged in dubious activities, introducing unaccounted money through questionable transactions. The CIT(A)'s order was upheld, ruling against the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
