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Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
The ITAT set aside and restored multiple issues to the file of the AO. The DRP's LIBOR+350 bps rate is held prima facie appropriate, but the AO is directed to require the assessee to benchmark the outstanding receivable by reference to the currency of invoicing and to determine ALP of the international transaction under s.92CA, applying suitable mark-up or reduction for transaction-specific risk; the assessee may argue working-capital adjustments for software/ITeS segments. A double addition made at s.143(1) and again in the final order is to be deleted. The AO must use the disclosed book profit of Rs.118,10,19,785 for s.115JB computation. Donations qualify for deduction under s.80G; AO to allow.
The ITAT set aside and restored multiple issues to the file of the AO. The DRP's LIBOR+350 bps rate is held prima facie appropriate, but the AO is directed to require the assessee to benchmark the outstanding receivable by reference to the currency of invoicing and to determine ALP of the international transaction under s.92CA, applying suitable mark-up or reduction for transaction-specific risk; the assessee may argue working-capital adjustments for software/ITeS segments. A double addition made at s.143(1) and again in the final order is to be deleted. The AO must use the disclosed book profit of Rs.118,10,19,785 for s.115JB computation. Donations qualify for deduction under s.80G; AO to allow.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
