Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Where reassessment is initiated under s.147 on recorded reasons, the AO must first make an addition on the very issue forming the basis of those reasons; if the AO accepts the explanation and makes no addition on the recorded-reasons issue, no other addition can be made on unrelated matters, and Expln. 3 to s.147 does not cure this defect. Since the AO made no addition regarding the cash deposits referred to in the reasons but instead made an addition under s.40A(3) without any recorded reason, the s.40A(3) addition was held unsustainable and directed to be deleted; the taxpayer's ground was allowed. - ITAT
Where reassessment is initiated under s.147 on recorded reasons, the AO must first make an addition on the very issue forming the basis of those reasons; if the AO accepts the explanation and makes no addition on the recorded-reasons issue, no other addition can be made on unrelated matters, and Expln. 3 to s.147 does not cure this defect. Since the AO made no addition regarding the cash deposits referred to in the reasons but instead made an addition under s.40A(3) without any recorded reason, the s.40A(3) addition was held unsustainable and directed to be deleted; the taxpayer's ground was allowed. - ITAT
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