Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Taxpayer denied deduction under section 80IA as they failed to meet statutory requirements for infrastructure development projects. ITAT found that LMRCL, being a special purpose vehicle with 50:50 equity between Central and State governments, did not qualify as government authority/statutory body under section 80IA(4). Assessee's role was limited to tunnel construction per contract specifications. Regarding disallowance of technical service fees paid to Gulemark TPL JV, ITAT reversed AO's decision, holding that expenses were legitimate business expenditures deductible under section 37. Since AO had accepted these as revenue expenditure rather than capital expenditure, technical service fees were allowed as claimed. Revenue's appeals dismissed.
Taxpayer denied deduction under section 80IA as they failed to meet statutory requirements for infrastructure development projects. ITAT found that LMRCL, being a special purpose vehicle with 50:50 equity between Central and State governments, did not qualify as government authority/statutory body under section 80IA(4). Assessee's role was limited to tunnel construction per contract specifications. Regarding disallowance of technical service fees paid to Gulemark TPL JV, ITAT reversed AO's decision, holding that expenses were legitimate business expenditures deductible under section 37. Since AO had accepted these as revenue expenditure rather than capital expenditure, technical service fees were allowed as claimed. Revenue's appeals dismissed.
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