Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
During a 2014 search operation, seized cash adjustment against advance tax liability was denied per Section 132B and Explanation 2. ITAT held that while self-assessment tax qualifies as 'existing liability', the assessee failed to include seized cash in total income computation. The matter of adjusting seized cash against self-assessment tax was remanded to AO for verification of circumstances similar to precedent case. Regarding interest u/s 220, ITAT ruled the assessee cannot be deemed in default as seized cash was already with Department within 30-day notice period. AO directed to adjust seized cash against tax liability if self-assessment tax adjustment relief is denied post verification.
During a 2014 search operation, seized cash adjustment against advance tax liability was denied per Section 132B and Explanation 2. ITAT held that while self-assessment tax qualifies as 'existing liability', the assessee failed to include seized cash in total income computation. The matter of adjusting seized cash against self-assessment tax was remanded to AO for verification of circumstances similar to precedent case. Regarding interest u/s 220, ITAT ruled the assessee cannot be deemed in default as seized cash was already with Department within 30-day notice period. AO directed to adjust seized cash against tax liability if self-assessment tax adjustment relief is denied post verification.
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