Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
HC allowed the appeal regarding depreciation on goodwill post-demerger for AYs 2015-16 and 2016-17. The court determined that the 5th proviso to Sec 32 only applies in the year of succession regarding aggregate deduction by predecessor and successor, not subsequent years. The Tribunal erroneously based its judgment solely on the Fifth Proviso's applicability, which was irrelevant for the assessment years in question. The scheme became effective in FY 2013-14, making the proviso applicable only for AY 2014-15. Matter remitted to Tribunal for fresh examination, considering the proviso's temporal scope and aggregate deduction requirement. Original Tribunal order dated 03 February 2023 set aside.
HC allowed the appeal regarding depreciation on goodwill post-demerger for AYs 2015-16 and 2016-17. The court determined that the 5th proviso to Sec 32 only applies in the year of succession regarding aggregate deduction by predecessor and successor, not subsequent years. The Tribunal erroneously based its judgment solely on the Fifth Proviso's applicability, which was irrelevant for the assessment years in question. The scheme became effective in FY 2013-14, making the proviso applicable only for AY 2014-15. Matter remitted to Tribunal for fresh examination, considering the proviso's temporal scope and aggregate deduction requirement. Original Tribunal order dated 03 February 2023 set aside.
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