International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
Reassessment notice under section 148 was sustained because the Assessing Officer had independent information forming reasons to believe that income had escaped assessment by a wrong claim of deduction; accordingly reassessment proceedings were validly initiated. On the substantive claim under section 80IB(10), the notional entry arising from a joint venture accounting valuation did not represent real income in the relevant year as no approved housing project activity, sales or completion occurred; applying the real income principle and to avoid double taxation, the disallowance of the deduction was deleted and the related additions were reversed.
Reassessment notice under section 148 was sustained because the Assessing Officer had independent information forming reasons to believe that income had escaped assessment by a wrong claim of deduction; accordingly reassessment proceedings were validly initiated. On the substantive claim under section 80IB(10), the notional entry arising from a joint venture accounting valuation did not represent real income in the relevant year as no approved housing project activity, sales or completion occurred; applying the real income principle and to avoid double taxation, the disallowance of the deduction was deleted and the related additions were reversed.
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