Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
ITAT held that additions for alleged capital gains and unexplained cash under section 69A, founded solely on uncorroborated personal diary entries and retracted statements of employees/directors, lacked evidentiary foundation and were deleted. Reassessment proceedings initiated by the jurisdictional AO were declared void ab initio as jurisdiction had vested in the Faceless Assessing Officer under the notified scheme; consequently the section 148 notice was coram non judice. The assessment order was also vitiated for failure to generate/quote a valid pre-generated DIN, rendering it a nullity. The appellate enhancement sought by Revenue was held not maintainable for want of cogent material within the scope of matters before the AO/CIT(A).
ITAT held that additions for alleged capital gains and unexplained cash under section 69A, founded solely on uncorroborated personal diary entries and retracted statements of employees/directors, lacked evidentiary foundation and were deleted. Reassessment proceedings initiated by the jurisdictional AO were declared void ab initio as jurisdiction had vested in the Faceless Assessing Officer under the notified scheme; consequently the section 148 notice was coram non judice. The assessment order was also vitiated for failure to generate/quote a valid pre-generated DIN, rendering it a nullity. The appellate enhancement sought by Revenue was held not maintainable for want of cogent material within the scope of matters before the AO/CIT(A).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4792
Join Channel
TaxTMI 
