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...
Duty drawback was held taxable on actual receipt in the previous year, as section 145B(3), read with section 2(24)(xviii), deems such income to accrue when received by the assessee. The Tribunal found that the assessee's bank records reflected only the amount credited in the profit and loss account, while the AO relied on unconfronted CBEC portal data without furnishing supporting details or independent proof of higher receipt. The differential addition was therefore deleted. As the penalty under section 270A(1) was wholly consequential to the deleted addition and no misreporting survived, the penalty was also set aside.
Duty drawback was held taxable on actual receipt in the previous year, as section 145B(3), read with section 2(24)(xviii), deems such income to accrue when received by the assessee. The Tribunal found that the assessee's bank records reflected only the amount credited in the profit and loss account, while the AO relied on unconfronted CBEC portal data without furnishing supporting details or independent proof of higher receipt. The differential addition was therefore deleted. As the penalty under section 270A(1) was wholly consequential to the deleted addition and no misreporting survived, the penalty was also set aside.
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