Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transfer pricing issue: preference share investment was treated as a disguised loan and recharacterised for TP purposes on substance-over-form grounds; DRP/TPO conclusion was affirmed and interest benchmarked accordingly. Disallowance under exempt-income allocation: the assessee's suo motu ad hoc apportionment of employee and overhead costs was rejected as unsupported. Interest disallowance against investments was denied where interest free funds exceeded investments; administrative disallowance to be recomputed per relevant precedent. An additional ground on cost attribution for captive steam was refused; AO correctly attributed full plant cost to electricity, eliminating the 80 IA deduction. Interest deduction for acquisition of control denied for lack of nexus; alternative claim against dividend income rejected. Matters on post retirement medical provision and in house R&D expenditure restored to AO for factual examination; AO directed to consider rectification for foreign tax credit.
Transfer pricing issue: preference share investment was treated as a disguised loan and recharacterised for TP purposes on substance-over-form grounds; DRP/TPO conclusion was affirmed and interest benchmarked accordingly. Disallowance under exempt-income allocation: the assessee's suo motu ad hoc apportionment of employee and overhead costs was rejected as unsupported. Interest disallowance against investments was denied where interest free funds exceeded investments; administrative disallowance to be recomputed per relevant precedent. An additional ground on cost attribution for captive steam was refused; AO correctly attributed full plant cost to electricity, eliminating the 80 IA deduction. Interest deduction for acquisition of control denied for lack of nexus; alternative claim against dividend income rejected. Matters on post retirement medical provision and in house R&D expenditure restored to AO for factual examination; AO directed to consider rectification for foreign tax credit.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
