Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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The ITAT considered the issue of set off of carried forward losses against current year profit due to a change in shareholding. Section 79 application was disputed, with the assessee arguing it pertains only to business loss, not unabsorbed depreciation. Legal precedent, including a Supreme Court ruling, clarified that section 79 does not cover unabsorbed depreciation. The ITAT directed the AO to verify if the losses in question include unabsorbed depreciation for set off against future profits. The appeal was allowed with this condition.
The ITAT considered the issue of set off of carried forward losses against current year profit due to a change in shareholding. Section 79 application was disputed, with the assessee arguing it pertains only to business loss, not unabsorbed depreciation. Legal precedent, including a Supreme Court ruling, clarified that section 79 does not cover unabsorbed depreciation. The ITAT directed the AO to verify if the losses in question include unabsorbed depreciation for set off against future profits. The appeal was allowed with this condition.
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