Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Goodwill amortisation was held to be an extraordinary/non operating expense for PLI computation under the TNMM and must be treated as non operating with corresponding adjustment to the PLI when computing ALP; the matter was remanded to AO/TPO only for verification whether depreciation was claimed and for giving the assessee opportunity of hearing. The Tribunal found the lower authorities misconstrued an earlier direction, directed AO/TPO to adjust PLI accordingly, and held initiation of penalty proceedings as premature and dismissed them.
Goodwill amortisation was held to be an extraordinary/non operating expense for PLI computation under the TNMM and must be treated as non operating with corresponding adjustment to the PLI when computing ALP; the matter was remanded to AO/TPO only for verification whether depreciation was claimed and for giving the assessee opportunity of hearing. The Tribunal found the lower authorities misconstrued an earlier direction, directed AO/TPO to adjust PLI accordingly, and held initiation of penalty proceedings as premature and dismissed them.
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