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...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
The Income Tax Appellate Tribunal (ITAT) ruled that when an assessee promptly computed and paid advance tax u/ss 234A, 234B, and 234C of the Income Tax Act, and an unanticipated capital gain transaction occurred in the fourth quarter, the liability to pay advance tax on the capital gain arises only after the transaction takes place. Since the assessee discharged the advance tax liability u/s 234C on March 31, 2019, after the capital gain accrued, and the department did not allege non-payment of the entire tax due, including capital gains, no interest u/s 234C was warranted. Relying on the case of M/S HAMILTON INDUSTRIES PVT. LTD., the ITAT directed the deletion of interest of Rs. 1,18,52,988/- and partially allowed the assessee's appeal.
The Income Tax Appellate Tribunal (ITAT) ruled that when an assessee promptly computed and paid advance tax u/ss 234A, 234B, and 234C of the Income Tax Act, and an unanticipated capital gain transaction occurred in the fourth quarter, the liability to pay advance tax on the capital gain arises only after the transaction takes place. Since the assessee discharged the advance tax liability u/s 234C on March 31, 2019, after the capital gain accrued, and the department did not allege non-payment of the entire tax due, including capital gains, no interest u/s 234C was warranted. Relying on the case of M/S HAMILTON INDUSTRIES PVT. LTD., the ITAT directed the deletion of interest of Rs. 1,18,52,988/- and partially allowed the assessee's appeal.
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