Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Penalty under section 270A could not be adjudicated because the quantum addition forming its basis had already been restored for fresh consideration under the applicable double taxation avoidance agreement. With the underlying addition no longer final, the penalty appeal was premature. The matter was therefore sent back for fresh decision by the Assessing Officer, who was directed to consider whether penalty proceedings should be initiated only after the outcome of the quantum proceedings.
Penalty under section 270A could not be adjudicated because the quantum addition forming its basis had already been restored for fresh consideration under the applicable double taxation avoidance agreement. With the underlying addition no longer final, the penalty appeal was premature. The matter was therefore sent back for fresh decision by the Assessing Officer, who was directed to consider whether penalty proceedings should be initiated only after the outcome of the quantum proceedings.
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