Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
ITAT held that a scrutiny notice under section 143(2) was invalid because it was not issued in the CBDT-prescribed format, and quashed the assessment as void ab initio. On merits, it held that capital gains on two Mumbai offices were not taxable in the later year because the assessee had already sold the property, handed over possession and received consideration earlier. It allowed cost of improvement for land at Visakhapatnam and accepted the indexed cost and improvement claim for Jagi Road land, holding that old audited book entries and a valuer's report could not be rejected without reasons. It also deleted taxation of rent again in the year of receipt under the mercantile system and allowed club-related business expenditure on commercial expediency.
ITAT held that a scrutiny notice under section 143(2) was invalid because it was not issued in the CBDT-prescribed format, and quashed the assessment as void ab initio. On merits, it held that capital gains on two Mumbai offices were not taxable in the later year because the assessee had already sold the property, handed over possession and received consideration earlier. It allowed cost of improvement for land at Visakhapatnam and accepted the indexed cost and improvement claim for Jagi Road land, holding that old audited book entries and a valuer's report could not be rejected without reasons. It also deleted taxation of rent again in the year of receipt under the mercantile system and allowed club-related business expenditure on commercial expediency.
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