Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
ITAT modified profit margins for undisclosed income in hotel/restaurant and real estate businesses following search and seizure action. For hotel/restaurant operations, tribunal reduced profit margin from 50% to 40% based on historical book profits ranging from 31-47%. For real estate transactions, margin lowered from 17% to 13% considering actual profit ratios. Regarding unsecured loans under Section 68, ITAT reversed CIT(A)'s deletion and upheld AO's additions, citing absence of incriminating materials during search and applying Abhisar Buildwell precedent. Court emphasized that seized materials must be considered in totality, rejecting selective interpretation, and maintained that only real income can be taxed following Godhra Electricity principles.
ITAT modified profit margins for undisclosed income in hotel/restaurant and real estate businesses following search and seizure action. For hotel/restaurant operations, tribunal reduced profit margin from 50% to 40% based on historical book profits ranging from 31-47%. For real estate transactions, margin lowered from 17% to 13% considering actual profit ratios. Regarding unsecured loans under Section 68, ITAT reversed CIT(A)'s deletion and upheld AO's additions, citing absence of incriminating materials during search and applying Abhisar Buildwell precedent. Court emphasized that seized materials must be considered in totality, rejecting selective interpretation, and maintained that only real income can be taxed following Godhra Electricity principles.
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