Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT dismissed Revenue's appeal regarding additions under Section 68 and brokerage expense disallowance. The Tribunal held that revaluation of assets by AOP (DD Associates) and subsequent credit to assessee's capital account did not trigger taxable income, as no actual transfer or sale occurred. The revaluation merely recognized present value in books without creating tax liability. The share adjustment from 46.50% to 5% was legitimate accounting entry, not a tax avoidance scheme. Regarding brokerage expenses, ITAT upheld CIT(A)'s deletion of disallowance since payments were made via cheque with TDS deduction and specific purpose was established. Both grounds decided in assessee's favor.
ITAT dismissed Revenue's appeal regarding additions under Section 68 and brokerage expense disallowance. The Tribunal held that revaluation of assets by AOP (DD Associates) and subsequent credit to assessee's capital account did not trigger taxable income, as no actual transfer or sale occurred. The revaluation merely recognized present value in books without creating tax liability. The share adjustment from 46.50% to 5% was legitimate accounting entry, not a tax avoidance scheme. Regarding brokerage expenses, ITAT upheld CIT(A)'s deletion of disallowance since payments were made via cheque with TDS deduction and specific purpose was established. Both grounds decided in assessee's favor.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
