Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
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ITAT allowed the assessee's additional claim, holding that while the AO may lack jurisdiction to adjudicate an additional claim absent a revised return, the appellate authority possesses jurisdiction to admit such a claim. The Tribunal found prima facie merit in the assessee's contention that she is a not-ordinarily-resident and not a resident, and that certain foreign income should therefore not be taxable in India. The appeal was remitted to the AO for a limited purpose: to verify the assessee's period of stay from 01.04.2005 to 31.03.2012 under section 6(6) of the Income-tax Act, determine residential status, and grant any reliefs as per law. Grounds 1 and 2 were allowed for statistical purposes.
ITAT allowed the assessee's additional claim, holding that while the AO may lack jurisdiction to adjudicate an additional claim absent a revised return, the appellate authority possesses jurisdiction to admit such a claim. The Tribunal found prima facie merit in the assessee's contention that she is a not-ordinarily-resident and not a resident, and that certain foreign income should therefore not be taxable in India. The appeal was remitted to the AO for a limited purpose: to verify the assessee's period of stay from 01.04.2005 to 31.03.2012 under section 6(6) of the Income-tax Act, determine residential status, and grant any reliefs as per law. Grounds 1 and 2 were allowed for statistical purposes.
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