Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
ITAT held: the challenge to the assessment under s.153 is kept open pending adjudication before the Hon'ble SC; AO directed to give effect to the SC outcome in the pending proceedings. Claim for deduction under s.80IA was remanded to the AO for factual verification under the second proviso to s.80IA(4) to determine whether the projects commenced development or O&M on/after 1.4.2017, precluding a conclusive appellate finding. On TP adjustments, ITAT found the specified domestic transactions benchmarked on CUP valid: where the AE passed government receipts to the assessee without mark-up under back-to-back contracts, those receipts constituted ALP; TPO's reallocation of corporate costs exceeded TP scope, so AO's TP additions were deleted.
ITAT held: the challenge to the assessment under s.153 is kept open pending adjudication before the Hon'ble SC; AO directed to give effect to the SC outcome in the pending proceedings. Claim for deduction under s.80IA was remanded to the AO for factual verification under the second proviso to s.80IA(4) to determine whether the projects commenced development or O&M on/after 1.4.2017, precluding a conclusive appellate finding. On TP adjustments, ITAT found the specified domestic transactions benchmarked on CUP valid: where the AE passed government receipts to the assessee without mark-up under back-to-back contracts, those receipts constituted ALP; TPO's reallocation of corporate costs exceeded TP scope, so AO's TP additions were deleted.
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