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Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
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Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
The Tribunal held that the onus was on the Revenue to demonstrate the Appellant's default leading to inordinate delay in allotment of shares, which the Revenue failed to discharge. Consequently, the transfer pricing adjustment treating share application money as an interest-free loan to the Associated Enterprise was deleted. Regarding the Dispute Resolution Panel's failure to consider the Assessing Officer's rectification order u/s 154 revising the income, the Assessing Officer was directed to recompute the income and tax liability after considering the rectification order. The Tribunal allowed the grounds raised by the Appellant on these issues.
The Tribunal held that the onus was on the Revenue to demonstrate the Appellant's default leading to inordinate delay in allotment of shares, which the Revenue failed to discharge. Consequently, the transfer pricing adjustment treating share application money as an interest-free loan to the Associated Enterprise was deleted. Regarding the Dispute Resolution Panel's failure to consider the Assessing Officer's rectification order u/s 154 revising the income, the Assessing Officer was directed to recompute the income and tax liability after considering the rectification order. The Tribunal allowed the grounds raised by the Appellant on these issues.
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