Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The consent decree u/s 50C granted absolute ownership rights to Smt. Manju Agarwal over the 1314 sq.ft. office premises, allowing her to use, enjoy, and deal with it without objection. The property was sold by Nav Technology Pvt. Ltd., represented by Ms. Anmol Agarwal, without authority from other directors. The executing court cannot direct a person other than the vendor to bear tax liability arising from the transaction, as it would violate Income Tax Act provisions. While the judgment-debtors disregarded the decree's intention, the court cannot ask Smt. Manju Agarwal to shoulder tax responsibility at this stage. Further evidence is required regarding surrender or surrender value of the VIP Road property. As some decree obligations have been complied with, the other prayers cannot be allowed without specific details.
The consent decree u/s 50C granted absolute ownership rights to Smt. Manju Agarwal over the 1314 sq.ft. office premises, allowing her to use, enjoy, and deal with it without objection. The property was sold by Nav Technology Pvt. Ltd., represented by Ms. Anmol Agarwal, without authority from other directors. The executing court cannot direct a person other than the vendor to bear tax liability arising from the transaction, as it would violate Income Tax Act provisions. While the judgment-debtors disregarded the decree's intention, the court cannot ask Smt. Manju Agarwal to shoulder tax responsibility at this stage. Further evidence is required regarding surrender or surrender value of the VIP Road property. As some decree obligations have been complied with, the other prayers cannot be allowed without specific details.
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TaxTMI 
TaxTMI 
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