Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Assessments u/s 153A for AYs 2012-13, 2013-14 & 2014-15 were made based on statement of third party and material from search of third party, without any incriminating material found in assessee's case. As per SC ruling in Pr. CIT v. Abhisar Buildwell, such additions are impermissible u/s 153A. For abated AYs 2015-16 onwards, AO's powers aren't limited to incriminating material from search. However, where AO accepted assessee's explanation on source of funds based on documentary evidence in remand report, CIT(A) erred in brushing it aside without substantive reasons. Additions sustained by CIT(A) despite AO's findings in remand report are unsustainable.
Assessments u/s 153A for AYs 2012-13, 2013-14 & 2014-15 were made based on statement of third party and material from search of third party, without any incriminating material found in assessee's case. As per SC ruling in Pr. CIT v. Abhisar Buildwell, such additions are impermissible u/s 153A. For abated AYs 2015-16 onwards, AO's powers aren't limited to incriminating material from search. However, where AO accepted assessee's explanation on source of funds based on documentary evidence in remand report, CIT(A) erred in brushing it aside without substantive reasons. Additions sustained by CIT(A) despite AO's findings in remand report are unsustainable.
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