Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
HC upheld the tax authorities' determination that the disputed land was not agricultural land under Section 2(14)(iii) of the Income Tax Act, making gains from its sale taxable as capital gains. Despite 7/12 land revenue extracts showing agricultural status, three authorities consistently found no actual agricultural use by the assessee after evaluating all evidence. The court declined to reassess evidence sufficiency, noting its limited jurisdiction under Section 260A. The authorities' factual findings were deemed adequately supported by record evidence, distinguishing this case from Shri Shankar Dalal where arbitrary land classification was overturned. The appeal was dismissed, confirming the land's non-agricultural status for tax purposes.
HC upheld the tax authorities' determination that the disputed land was not agricultural land under Section 2(14)(iii) of the Income Tax Act, making gains from its sale taxable as capital gains. Despite 7/12 land revenue extracts showing agricultural status, three authorities consistently found no actual agricultural use by the assessee after evaluating all evidence. The court declined to reassess evidence sufficiency, noting its limited jurisdiction under Section 260A. The authorities' factual findings were deemed adequately supported by record evidence, distinguishing this case from Shri Shankar Dalal where arbitrary land classification was overturned. The appeal was dismissed, confirming the land's non-agricultural status for tax purposes.
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TaxTMI 
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