Corporate guarantee valuation permits actual ascertainable commission while barring retroactive application and extended-period penalties for bona fid...
Proper-officer jurisdiction under UPGST penalty provisions upheld; participation on merits prevents bypassing the statutory appellate remedy through w...
Transitioned CENVAT credit may validly satisfy mandatory pre-deposit requirements for legacy service tax appeals through Electronic Credit Ledger debi...
Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
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The HC upheld the factual findings of the ITAT and CIT(A) that construction commenced after 1st October 1998, entitling the assessee to claim deduction under section 80IB(10), subject to other conditions. Regarding disallowance under section 14A read with Rule 8D, the HC concurred with the ITAT that Rule 8D applies prospectively from AY 2008-09 onwards. Consequently, the CIT(A)'s restriction of disallowance to 10% of exempt income was upheld as valid. The Court found no substantial question of law warranting interference, affirming the lower authorities' decisions on both issues.
The HC upheld the factual findings of the ITAT and CIT(A) that construction commenced after 1st October 1998, entitling the assessee to claim deduction under section 80IB(10), subject to other conditions. Regarding disallowance under section 14A read with Rule 8D, the HC concurred with the ITAT that Rule 8D applies prospectively from AY 2008-09 onwards. Consequently, the CIT(A)'s restriction of disallowance to 10% of exempt income was upheld as valid. The Court found no substantial question of law warranting interference, affirming the lower authorities' decisions on both issues.
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