Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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...
Three key issues: validity of reopening assessment, treatment of short-term capital gain on sale of factory building, and disallowance of short-term capital loss on share transactions. Regarding reopening, the assessee failed to provide evidence challenging the reassessment proceedings initiated u/s 148. On the factory building sale, the Tribunal upheld adopting the market value as on the conveyance deed date rather than the earlier business transfer agreement date. Concerning the share transactions, the Tribunal upheld the disallowance of claimed capital loss due to lack of evidence justifying the wide fluctuation in share values within a short period and absence of supporting documents like valuation reports, bank statements, and confirmations from counterparties. The Tribunal found no infirmity in the CIT(A)'s order on these issues.
Three key issues: validity of reopening assessment, treatment of short-term capital gain on sale of factory building, and disallowance of short-term capital loss on share transactions. Regarding reopening, the assessee failed to provide evidence challenging the reassessment proceedings initiated u/s 148. On the factory building sale, the Tribunal upheld adopting the market value as on the conveyance deed date rather than the earlier business transfer agreement date. Concerning the share transactions, the Tribunal upheld the disallowance of claimed capital loss due to lack of evidence justifying the wide fluctuation in share values within a short period and absence of supporting documents like valuation reports, bank statements, and confirmations from counterparties. The Tribunal found no infirmity in the CIT(A)'s order on these issues.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
