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...
Disallowance of stamp duty/fees paid for increase in authorised share capital turned on whether the expenditure was claimed as a deductible revenue outlay. The tribunal found, from the balance sheet note on "other equity" and the tax audit report, that the amount was directly adjusted in retained earnings as share issue expenses and was not routed through the P&L account as revenue expenditure. Since no deduction had been claimed in computing taxable income, there was no basis for any disallowance. The disallowance was deleted and the appeal was allowed. - ITAT
Disallowance of stamp duty/fees paid for increase in authorised share capital turned on whether the expenditure was claimed as a deductible revenue outlay. The tribunal found, from the balance sheet note on "other equity" and the tax audit report, that the amount was directly adjusted in retained earnings as share issue expenses and was not routed through the P&L account as revenue expenditure. Since no deduction had been claimed in computing taxable income, there was no basis for any disallowance. The disallowance was deleted and the appeal was allowed. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4826 
Join Channel 
