Reassessment for unreturned property sales survives where transfer information, non-filing, and unsupported exemption claims establish a prima facie l...
Profit-element taxation limits additions for unaccounted flat-sale receipts and grey-market purchases, while reliable search records support partial a...
Non-participating bidders cannot disturb concluded liquidation sales on speculative prejudice, while costs for such challenges must remain proportiona...
The ITAT held that identical issues arose in the assessee's own case for AY 2019-20 which was decided in favour of the assessee, thus there is no justification in attributing the profit on offshore sale of equipment. Regarding receipt from Glidepath, New Zealand, the ITAT found no artificial splitting of contracts and relied on the Supreme Court's decision in Morgan Stanley to hold that the receipt cannot be subjected to tax. For receipts from KITCOL, TTD and CIAL, the matter was restored to the AO to examine double taxation after the assessee furnishes evidence of offering the receipts in earlier years.
The ITAT held that identical issues arose in the assessee's own case for AY 2019-20 which was decided in favour of the assessee, thus there is no justification in attributing the profit on offshore sale of equipment. Regarding receipt from Glidepath, New Zealand, the ITAT found no artificial splitting of contracts and relied on the Supreme Court's decision in Morgan Stanley to hold that the receipt cannot be subjected to tax. For receipts from KITCOL, TTD and CIAL, the matter was restored to the AO to examine double taxation after the assessee furnishes evidence of offering the receipts in earlier years.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4884 
