Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Jurisdictional issue regarding notice u/s 143(2) was addressed, with ITAT holding that the initial notice by ACIT, Circle-5(1), Delhi was within time, and subsequent transfer to jurisdictional AO did not invalidate proceedings. Regarding addition u/ss 68/69C, ITAT held CIT(A) erred in making addition u/s 69C without issuing show cause notice as mandated u/s 251. Books of account were accepted by AO, who did not reject them or make efforts to verify sundry creditors. Additions u/s 68 cannot be made when sales, purchases, and gross profit were disclosed and accepted. CIT(A)'s addition u/s 69C on grounds of non-banking channel purchases was incorrect when sales were accepted and gross profit rate increased. ITAT deleted CIT(A)'s addition u/s 69C, allowing assessee's appeal.
Jurisdictional issue regarding notice u/s 143(2) was addressed, with ITAT holding that the initial notice by ACIT, Circle-5(1), Delhi was within time, and subsequent transfer to jurisdictional AO did not invalidate proceedings. Regarding addition u/ss 68/69C, ITAT held CIT(A) erred in making addition u/s 69C without issuing show cause notice as mandated u/s 251. Books of account were accepted by AO, who did not reject them or make efforts to verify sundry creditors. Additions u/s 68 cannot be made when sales, purchases, and gross profit were disclosed and accepted. CIT(A)'s addition u/s 69C on grounds of non-banking channel purchases was incorrect when sales were accepted and gross profit rate increased. ITAT deleted CIT(A)'s addition u/s 69C, allowing assessee's appeal.
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