Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
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The case pertains to the denial of exemption u/s 11 due to excessive payments made on account of salary and rent to persons specified u/s 13(3). The Assessing Officer (AO) had disallowed the payments made to specified persons. However, upon examination, it was found that the rent paid by the assessee was lower than the prevailing market rates in the same area paid by unrelated parties. The AO had relied on an agreement for a different premise in the same locality, leading to an appreciation of wrong facts. Consequently, the Appellate Tribunal (ITAT) held that the impugned payments were not excessive or unreasonable, deciding the case in favor of the assessee.
The case pertains to the denial of exemption u/s 11 due to excessive payments made on account of salary and rent to persons specified u/s 13(3). The Assessing Officer (AO) had disallowed the payments made to specified persons. However, upon examination, it was found that the rent paid by the assessee was lower than the prevailing market rates in the same area paid by unrelated parties. The AO had relied on an agreement for a different premise in the same locality, leading to an appreciation of wrong facts. Consequently, the Appellate Tribunal (ITAT) held that the impugned payments were not excessive or unreasonable, deciding the case in favor of the assessee.
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