Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
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Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The reopening of assessment proceedings u/s 147 was valid as the Assessing Officer (AO) had received information about the assessee booking tax loss through trade in shares, which could not be considered a mere change of opinion. The AO provided independent findings regarding trading in shares of M/s. Radhe Developers Ltd., and the assessee's objections were not tenable. The decisions in NDTV, Calcutta Discount, Parshuram Potteries, and Bombay Stock Exchange cases were not relevant as the reopening was specific to trading in M/s. Radhe Developers Ltd.'s scrip and not just a second opinion. However, the disallowance of loss in share trading was not sustained as the AO and CIT(A) did not correlate the trading with price fluctuations of M/s. Radhe Developers Ltd. or establish the assessee's involvement in price manipulation. The SEBI report and suspension of Bombay Stock Exchange in 2015 were not sufficient to disallow the loss in the assessment year 2011-12.
The reopening of assessment proceedings u/s 147 was valid as the Assessing Officer (AO) had received information about the assessee booking tax loss through trade in shares, which could not be considered a mere change of opinion. The AO provided independent findings regarding trading in shares of M/s. Radhe Developers Ltd., and the assessee's objections were not tenable. The decisions in NDTV, Calcutta Discount, Parshuram Potteries, and Bombay Stock Exchange cases were not relevant as the reopening was specific to trading in M/s. Radhe Developers Ltd.'s scrip and not just a second opinion. However, the disallowance of loss in share trading was not sustained as the AO and CIT(A) did not correlate the trading with price fluctuations of M/s. Radhe Developers Ltd. or establish the assessee's involvement in price manipulation. The SEBI report and suspension of Bombay Stock Exchange in 2015 were not sufficient to disallow the loss in the assessment year 2011-12.
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