Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
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...
In assessment u/s 153C, disallowance of depreciation on alleged bogus power-plant cost was deleted because the addition rested only on retracted oral statements, with no corroborative seized material linking alleged subcontractors to cash generation or showing incriminating material relatable to the relevant AY; proceedings could not be sustained on assumptions, so the revenue's grounds failed. Disallowance u/s 2(24)(x) r.w.s. 36(1)(va) for employees' PF contribution was directed to be deleted if bank balance existed and delay was solely due to technical glitches, subject to AO verification. Depreciation on new assets put to use in March was remanded to AO for fresh verification of purchase/use evidence. Reduction in insurance claim was sustained as duly supported. Depreciation on WDV of the power plant was allowed on consistency where no change in facts was shown. - ITAT
In assessment u/s 153C, disallowance of depreciation on alleged bogus power-plant cost was deleted because the addition rested only on retracted oral statements, with no corroborative seized material linking alleged subcontractors to cash generation or showing incriminating material relatable to the relevant AY; proceedings could not be sustained on assumptions, so the revenue's grounds failed. Disallowance u/s 2(24)(x) r.w.s. 36(1)(va) for employees' PF contribution was directed to be deleted if bank balance existed and delay was solely due to technical glitches, subject to AO verification. Depreciation on new assets put to use in March was remanded to AO for fresh verification of purchase/use evidence. Reduction in insurance claim was sustained as duly supported. Depreciation on WDV of the power plant was allowed on consistency where no change in facts was shown. - ITAT
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