Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Whether proceedings under Section 153C were validly initiated: Court held the foundational statutory prerequisite-creation of an asset under the scheme and the fourth proviso to Section 153A-appears absent because the ledger entries relate to expenditure and TDS was deducted, undermining the jurisdictional basis for a Section 153C notice; outcome: petitioner has a plausible ground to oppose the proceedings. Direction to assessing officer to decide petitioner's objections and pass a reasoned order within the specified short period, with communication to petitioner. - HC
Whether proceedings under Section 153C were validly initiated: Court held the foundational statutory prerequisite-creation of an asset under the scheme and the fourth proviso to Section 153A-appears absent because the ledger entries relate to expenditure and TDS was deducted, undermining the jurisdictional basis for a Section 153C notice; outcome: petitioner has a plausible ground to oppose the proceedings. Direction to assessing officer to decide petitioner's objections and pass a reasoned order within the specified short period, with communication to petitioner. - HC
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