Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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 4803
Join Channel
TaxTMI 
