Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The ITAT held that the extra profit share received by the assessee-HUF on revaluation and reconstitution of the partnership firm, credited as goodwill in the current account, does not constitute taxable income under section 28(iv) of the Act. The arrangement was held to be a family arrangement rather than a business arrangement, negating the revenue's claim. The AO's treatment of the amount withdrawn as income under section 28(iv) was reversed, affirming the CIT(A)'s order. Regarding reopening under section 147, the AO failed to record valid reasons or provide them to the assessee, violating mandatory procedural requirements. The absence of a speaking order disposing of objections rendered the reassessment invalid. Consequently, the reopening and reassessment orders for AYs 2015-16 and 2016-17 were quashed, and the appeal was allowed.
The ITAT held that the extra profit share received by the assessee-HUF on revaluation and reconstitution of the partnership firm, credited as goodwill in the current account, does not constitute taxable income under section 28(iv) of the Act. The arrangement was held to be a family arrangement rather than a business arrangement, negating the revenue's claim. The AO's treatment of the amount withdrawn as income under section 28(iv) was reversed, affirming the CIT(A)'s order. Regarding reopening under section 147, the AO failed to record valid reasons or provide them to the assessee, violating mandatory procedural requirements. The absence of a speaking order disposing of objections rendered the reassessment invalid. Consequently, the reopening and reassessment orders for AYs 2015-16 and 2016-17 were quashed, and the appeal was allowed.
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