Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The ITAT allowed the appeal of the assessee-trust, holding that the addition of Rs. 44,00,000/- made under s. 143(1) was unsustainable. The CPC had accepted all deductions claimed under ss. 11 and 10(23C), but committed an arithmetical error by incorrectly totaling the deductions at Rs. 7,52,41,564/- instead of Rs. 7,96,41,565/-. This miscalculation led to an erroneous computation of income purportedly chargeable under s. 11(1B), though the figure of Rs. 44,00,000/- was consistently reflected by both the assessee and CPC. ITAT held that the variation stemmed solely from CPC's totaling mistake, not from any disallowance or difference in claim, and therefore directed deletion of the entire addition.
The ITAT allowed the appeal of the assessee-trust, holding that the addition of Rs. 44,00,000/- made under s. 143(1) was unsustainable. The CPC had accepted all deductions claimed under ss. 11 and 10(23C), but committed an arithmetical error by incorrectly totaling the deductions at Rs. 7,52,41,564/- instead of Rs. 7,96,41,565/-. This miscalculation led to an erroneous computation of income purportedly chargeable under s. 11(1B), though the figure of Rs. 44,00,000/- was consistently reflected by both the assessee and CPC. ITAT held that the variation stemmed solely from CPC's totaling mistake, not from any disallowance or difference in claim, and therefore directed deletion of the entire addition.
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