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...
Transfer of case u/s 127 - sufficient material existed for transfer from Income Tax Office, Corporate Ward-2(3), Chennai to DCIT, Circle-4(4), Kolkata ('Central Circle'). Search and seizure u/s 132 revealed incriminating documents connecting petitioner's involvement in lottery business operations in West Bengal as sub-distributor, stockist, printing press, etc. Considering petitioner's reply, transfer ordered to centralize investigation along with eight other similar cases. Contentions of lack of opportunity or insufficient material rejected. Transfer for coordinated investigation in public interest permissible despite inconvenience. No prejudice caused as no adverse assessment order passed, only transfer u/s 127. Strict interpretation of taxing statute warranted. Writ petition dismissed.
Transfer of case u/s 127 - sufficient material existed for transfer from Income Tax Office, Corporate Ward-2(3), Chennai to DCIT, Circle-4(4), Kolkata ('Central Circle'). Search and seizure u/s 132 revealed incriminating documents connecting petitioner's involvement in lottery business operations in West Bengal as sub-distributor, stockist, printing press, etc. Considering petitioner's reply, transfer ordered to centralize investigation along with eight other similar cases. Contentions of lack of opportunity or insufficient material rejected. Transfer for coordinated investigation in public interest permissible despite inconvenience. No prejudice caused as no adverse assessment order passed, only transfer u/s 127. Strict interpretation of taxing statute warranted. Writ petition dismissed.
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