Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Assumption of jurisdiction u/s 153A was challenged due to unexplained credit u/s 68. Share capital, being a liability, cannot be treated as an asset to invoke jurisdiction. AO could go beyond 6 years only if certain income represented as an asset escaped assessment, which was missing here. CIT(A) rightly held share capital is not an asset since it represents assessee's liability. AO's attempt to treat share capital as an asset was erroneous, rendering jurisdiction untenable. Goldstone Cements Ltd. case supported this view, ruling AO cannot assume jurisdiction for liabilities. When AO fails to make addition for undisclosed asset, it implies lack of jurisdictional fact initially, wrongly assuming jurisdiction u/s 153A. Decided against revenue.
Assumption of jurisdiction u/s 153A was challenged due to unexplained credit u/s 68. Share capital, being a liability, cannot be treated as an asset to invoke jurisdiction. AO could go beyond 6 years only if certain income represented as an asset escaped assessment, which was missing here. CIT(A) rightly held share capital is not an asset since it represents assessee's liability. AO's attempt to treat share capital as an asset was erroneous, rendering jurisdiction untenable. Goldstone Cements Ltd. case supported this view, ruling AO cannot assume jurisdiction for liabilities. When AO fails to make addition for undisclosed asset, it implies lack of jurisdictional fact initially, wrongly assuming jurisdiction u/s 153A. Decided against revenue.
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