Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The ITAT upheld the validity of the reassessment proceedings, holding that in the given factual matrix, where the assessee persistently failed to comply with statutory notices and the assessment was completed u/s 144, non-issuance of notice u/s 143(2) after a belated return in response to notice u/s 148 did not vitiate the assessment or the jurisdiction assumed u/s 147. However, on the merits of additions towards alleged bogus LTCG and accommodation entries, the ITAT found that the trades were speculative transactions u/s 43(5), duly supported by broker records and bank statements, and that the AO and CIT(A) had made additions purely on conjecture without basic inquiry or tangible material. Consequently, the ITAT deleted the sustained additions of Rs. 1,53,633 and Rs. 25,79,787, granting substantive relief to the assessee on quantum while maintaining the reassessment's legal validity.
The ITAT upheld the validity of the reassessment proceedings, holding that in the given factual matrix, where the assessee persistently failed to comply with statutory notices and the assessment was completed u/s 144, non-issuance of notice u/s 143(2) after a belated return in response to notice u/s 148 did not vitiate the assessment or the jurisdiction assumed u/s 147. However, on the merits of additions towards alleged bogus LTCG and accommodation entries, the ITAT found that the trades were speculative transactions u/s 43(5), duly supported by broker records and bank statements, and that the AO and CIT(A) had made additions purely on conjecture without basic inquiry or tangible material. Consequently, the ITAT deleted the sustained additions of Rs. 1,53,633 and Rs. 25,79,787, granting substantive relief to the assessee on quantum while maintaining the reassessment's legal validity.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
