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...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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ITAT held the reassessment invalid and set aside the reopening. The Tribunal found the AO had examined and allowed the assessee's deduction under s.80IA during original assessment on receipt of Form 10CCB and project accounts, and the reassessment was prompted solely by a change of opinion without fresh tangible material. The Revenue's alternative grounds - reduction of s.80IA profits in computing other Chapter VIA deductions, concurrent claims under s.80HHC and s.80HHE, and disallowance of prior period expenses - were rejected as contrary to binding principles and on facts. The reassessment order was quashed and the assessee's assessments restored.
ITAT held the reassessment invalid and set aside the reopening. The Tribunal found the AO had examined and allowed the assessee's deduction under s.80IA during original assessment on receipt of Form 10CCB and project accounts, and the reassessment was prompted solely by a change of opinion without fresh tangible material. The Revenue's alternative grounds - reduction of s.80IA profits in computing other Chapter VIA deductions, concurrent claims under s.80HHC and s.80HHE, and disallowance of prior period expenses - were rejected as contrary to binding principles and on facts. The reassessment order was quashed and the assessee's assessments restored.
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