Transition support services from corporate spinoff for India business segment - TP adjustment deleted; comparables reassessed; goodwill depreciation, ...
Qualification of fire extinguishers as aircraft parts - original duty finding under Notification No.50/2017-Sr.545 vacated; remanded for fresh adjudic...
Reopening after search was held time barred for the 2012-13 assessment as the notice under section 148 fell outside the ten year limitation and the reassessment was quashed. The note states that only the profit element of undisclosed 'on money' is taxable, and a uniform estimation rate of 10% was applied on the facts. Unaccounted profit is taxable in the year of execution of the sale deed (transfer), with ICDS III inapplicable. Issues of alleged negative cash balances were remitted to the AO for verification. Telescoping deletions under unexplained money were upheld where an assessed profit exceeded other applications, and a seized ledger corroborated a short term capital gain addition.
Reopening after search was held time barred for the 2012-13 assessment as the notice under section 148 fell outside the ten year limitation and the reassessment was quashed. The note states that only the profit element of undisclosed 'on money' is taxable, and a uniform estimation rate of 10% was applied on the facts. Unaccounted profit is taxable in the year of execution of the sale deed (transfer), with ICDS III inapplicable. Issues of alleged negative cash balances were remitted to the AO for verification. Telescoping deletions under unexplained money were upheld where an assessed profit exceeded other applications, and a seized ledger corroborated a short term capital gain addition.
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