Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Assessee, a company paying taxes at fixed rate, filed claim for prior period depreciation. ITAT held allowance of prior period depreciation claim was tax neutral exercise, not resulting in revenue loss. Assessee entitled to claim unabsorbed depreciation of preceding year as depreciation of succeeding year u/s 32(2). Revisionary jurisdiction u/s 263 unwarranted as assessment order not erroneous causing prejudice to revenue. However, ITAT confirmed PCIT's order regarding non-examination of TDS on rent expenses by AO u/s 40(a)(ia), holding assessment order erroneous on this count. Appeal partly allowed.
Assessee, a company paying taxes at fixed rate, filed claim for prior period depreciation. ITAT held allowance of prior period depreciation claim was tax neutral exercise, not resulting in revenue loss. Assessee entitled to claim unabsorbed depreciation of preceding year as depreciation of succeeding year u/s 32(2). Revisionary jurisdiction u/s 263 unwarranted as assessment order not erroneous causing prejudice to revenue. However, ITAT confirmed PCIT's order regarding non-examination of TDS on rent expenses by AO u/s 40(a)(ia), holding assessment order erroneous on this count. Appeal partly allowed.
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