Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Repairs and maintenance on plant and machinery were examined to determine whether the outlay was capital or revenue. Since the expenditure involved only minor replacement of parts/pipelines and components of the effluent treatment system due to wear and tear, without replacement of an entire plant or creation of an enduring advantage, it was held to be revenue in nature; the enhanced disallowance was deleted. Professional fees were assessed for allowability under s. 37(1) where the authority treated certain items as relating to fresh share capital. Fees for share transfer work, reconciliation for share capital audit reporting, and listing of equity shares were held not to be for capital expansion and were allowed as revenue expenditure; the related disallowance was directed to be deleted. - ITAT
Repairs and maintenance on plant and machinery were examined to determine whether the outlay was capital or revenue. Since the expenditure involved only minor replacement of parts/pipelines and components of the effluent treatment system due to wear and tear, without replacement of an entire plant or creation of an enduring advantage, it was held to be revenue in nature; the enhanced disallowance was deleted. Professional fees were assessed for allowability under s. 37(1) where the authority treated certain items as relating to fresh share capital. Fees for share transfer work, reconciliation for share capital audit reporting, and listing of equity shares were held not to be for capital expansion and were allowed as revenue expenditure; the related disallowance was directed to be deleted. - ITAT
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