Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
ITAT dismissed revenue's appeal on multiple grounds. Regarding 'on-money' addition, ITAT upheld CIT(A)'s restriction to 25% of AO's addition, finding AO lacked evidentiary basis for extrapolation from 99acres.com reference prices. On transfer pricing adjustments for debenture interest and expenses, ITAT affirmed CIT(A)'s deletion, noting TPO failed to apply prescribed methods under section 92C(1) read with Rule 10AB for determining arm's length price. Court held CCD issuance was quasi-capital nature and cited Shell India Markets precedent that share issuance to non-resident associated enterprises doesn't attract transfer pricing provisions. For various business expenses disallowance, ITAT confirmed CIT(A)'s allowance, finding expenses were incurred wholly and exclusively for business purposes without capital or personal nature.
ITAT dismissed revenue's appeal on multiple grounds. Regarding 'on-money' addition, ITAT upheld CIT(A)'s restriction to 25% of AO's addition, finding AO lacked evidentiary basis for extrapolation from 99acres.com reference prices. On transfer pricing adjustments for debenture interest and expenses, ITAT affirmed CIT(A)'s deletion, noting TPO failed to apply prescribed methods under section 92C(1) read with Rule 10AB for determining arm's length price. Court held CCD issuance was quasi-capital nature and cited Shell India Markets precedent that share issuance to non-resident associated enterprises doesn't attract transfer pricing provisions. For various business expenses disallowance, ITAT confirmed CIT(A)'s allowance, finding expenses were incurred wholly and exclusively for business purposes without capital or personal nature.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
