Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
Where the tax authority replaced the consistently accepted project completion method with percentage completion for a single year to tax alleged undisclosed profit admitted in a sworn statement, the tribunal held that, absent any change in facts or law, the revenue could not unilaterally substitute the method of revenue recognition, and an addition based only on a survey/statement without corroborative evidence was unsustainable; the deletion of the undisclosed-profit addition was upheld. On stamp valuation adjustment, the tribunal held the 10% tolerance band in the amended proviso to section 43CA(1) is curative and applies retrospectively; since the variation was 7%, the section 43CA addition was deleted. Revenue's appeal was dismissed. - ITAT
Where the tax authority replaced the consistently accepted project completion method with percentage completion for a single year to tax alleged undisclosed profit admitted in a sworn statement, the tribunal held that, absent any change in facts or law, the revenue could not unilaterally substitute the method of revenue recognition, and an addition based only on a survey/statement without corroborative evidence was unsustainable; the deletion of the undisclosed-profit addition was upheld. On stamp valuation adjustment, the tribunal held the 10% tolerance band in the amended proviso to section 43CA(1) is curative and applies retrospectively; since the variation was 7%, the section 43CA addition was deleted. Revenue's appeal was dismissed. - ITAT
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