Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Appellant booked artificial short-term capital loss by purchasing shares from group entities at exorbitant rates and selling same shares to other group entities at lower rates to offset huge capital gains. Transaction lacked genuineness, designed solely to avoid taxes. Cost of purchase rightly recomputed by authorities at Rs.33 per share. Interest expenditure disallowed u/s 14A as appellant failed to substantiate investments were for strategic business purposes, admitted using interest-bearing funds for non-business investments yielding exempt income. CIT(A)'s order upheld, assessee's appeal dismissed by Appellate Tribunal.
Appellant booked artificial short-term capital loss by purchasing shares from group entities at exorbitant rates and selling same shares to other group entities at lower rates to offset huge capital gains. Transaction lacked genuineness, designed solely to avoid taxes. Cost of purchase rightly recomputed by authorities at Rs.33 per share. Interest expenditure disallowed u/s 14A as appellant failed to substantiate investments were for strategic business purposes, admitted using interest-bearing funds for non-business investments yielding exempt income. CIT(A)'s order upheld, assessee's appeal dismissed by Appellate Tribunal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
