Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
ITAT ruled in favor of assessee, setting aside revision under s.263 regarding goodwill depreciation claim post-amalgamation. The tribunal found PCIT's jurisdiction exercise erroneous, as evidence clearly showed trade receivables of Municipal Waste Division were never transferred to assessee under NCLT-approved amalgamation scheme. The AO had conducted detailed inquiry regarding goodwill depreciation during assessment proceedings. ITAT determined PCIT's revision was based on misconceived facts and incorrect assumption about transfer of trade receivables, making the s.263 revision order legally unsustainable. The assessee had provided comprehensive documentation including board resolutions and scheme details supporting their position.
ITAT ruled in favor of assessee, setting aside revision under s.263 regarding goodwill depreciation claim post-amalgamation. The tribunal found PCIT's jurisdiction exercise erroneous, as evidence clearly showed trade receivables of Municipal Waste Division were never transferred to assessee under NCLT-approved amalgamation scheme. The AO had conducted detailed inquiry regarding goodwill depreciation during assessment proceedings. ITAT determined PCIT's revision was based on misconceived facts and incorrect assumption about transfer of trade receivables, making the s.263 revision order legally unsustainable. The assessee had provided comprehensive documentation including board resolutions and scheme details supporting their position.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4830 
Join Channel 
