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...
The Tribunal treated the scrutiny as complete scrutiny because the assessment record itself showed that the case was not confined to limited scrutiny, so the objection based on CBDT Instruction No. 20/2015 failed. It also upheld denial of section 54G relief, finding no proof of sale deeds, acquisition of new assets, or actual shifting and continuation of the industrial undertaking. The disallowance of depreciation on the block of assets and the addition linked to transfer expenses in computing short-term capital gains were sustained for want of proper written down value adjustment and documentary evidence. Relief was granted only on loss on sale of fixed assets, where the reconciliation supported the assessee's computation.
The Tribunal treated the scrutiny as complete scrutiny because the assessment record itself showed that the case was not confined to limited scrutiny, so the objection based on CBDT Instruction No. 20/2015 failed. It also upheld denial of section 54G relief, finding no proof of sale deeds, acquisition of new assets, or actual shifting and continuation of the industrial undertaking. The disallowance of depreciation on the block of assets and the addition linked to transfer expenses in computing short-term capital gains were sustained for want of proper written down value adjustment and documentary evidence. Relief was granted only on loss on sale of fixed assets, where the reconciliation supported the assessee's computation.
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