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...
The ITAT upheld the assessee's entitlement to claim depreciation on leasehold improvements, affirming that the test of ownership is satisfied in such cases. However, regarding the addition of Rs. 4 crores to the sale consideration on the sale of shares, the Tribunal disagreed with the CIT(A)'s deletion of the addition. It held that the Rs. 4 crores was not a stipulated deduction under the contractual agreement, and the sale consideration was fixed at Rs. 16 crores without any provision for reduction by Rs. 4 crores. Consequently, the Tribunal set aside the CIT(A)'s order and confirmed the addition made by the AO. Grounds of appeal raised by the revenue on this issue were allowed, resulting in partial acceptance of the revenue's appeal and partial relief to the assessee.
The ITAT upheld the assessee's entitlement to claim depreciation on leasehold improvements, affirming that the test of ownership is satisfied in such cases. However, regarding the addition of Rs. 4 crores to the sale consideration on the sale of shares, the Tribunal disagreed with the CIT(A)'s deletion of the addition. It held that the Rs. 4 crores was not a stipulated deduction under the contractual agreement, and the sale consideration was fixed at Rs. 16 crores without any provision for reduction by Rs. 4 crores. Consequently, the Tribunal set aside the CIT(A)'s order and confirmed the addition made by the AO. Grounds of appeal raised by the revenue on this issue were allowed, resulting in partial acceptance of the revenue's appeal and partial relief to the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
