Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refus...
CKD/SKD air-conditioner components classifiable with finished units by essential character; prior advance ruling extended three years, FTA benefits po...
Scope of judicial review under Article 226: supervisory, not appellate; factual reappraisal barred, challenge dismissed; insolvency professional dutie...
Transfer of passive infrastructure assets pursuant to a court-approved demerger was held to constitute a "gift" covered by section 47(iii) and therefore not a "transfer" under section 2(47), negating the Revenue's case for depreciation-related disallowance; the Revenue's ground was dismissed. Network site rentals disallowed as excessive under section 40A(2)(b) were restored for de novo examination due to lack of factual inquiry into cost/value basis; remand ordered. Disallowance under section 14A was deleted as no exempt income was earned. Roaming charge disallowance under sections 40(a)(ia)/40(a)(i) for alleged TDS default was deleted, following binding precedent. Trade discounts on prepaid distribution were held outside section 194H; disallowance deleted. Multiple section 80IA claims (including SFIS income and allied receipts) were allowed applying section 80IA(2A), while variable license fee treatment was directed to be recomputed on amortisation after verification. Book profit under section 115JB was to be computed without importing Rule 8D. - ITAT
Transfer of passive infrastructure assets pursuant to a court-approved demerger was held to constitute a "gift" covered by section 47(iii) and therefore not a "transfer" under section 2(47), negating the Revenue's case for depreciation-related disallowance; the Revenue's ground was dismissed. Network site rentals disallowed as excessive under section 40A(2)(b) were restored for de novo examination due to lack of factual inquiry into cost/value basis; remand ordered. Disallowance under section 14A was deleted as no exempt income was earned. Roaming charge disallowance under sections 40(a)(ia)/40(a)(i) for alleged TDS default was deleted, following binding precedent. Trade discounts on prepaid distribution were held outside section 194H; disallowance deleted. Multiple section 80IA claims (including SFIS income and allied receipts) were allowed applying section 80IA(2A), while variable license fee treatment was directed to be recomputed on amortisation after verification. Book profit under section 115JB was to be computed without importing Rule 8D. - ITAT
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