Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Transfer pricing adjustment on AMP expenditure was deleted because the Bright Line Test could not be applied to determine arm's length price, following Delhi High Court and coordinate Bench precedent; the Tribunal held no adjustment was warranted on the assessee's AMP spend. The section 43B issue on bonus payment was not decided on merits and was remitted to verify whether the bonus was paid within the return-filing due date, in which case no addition would arise. Claims relating to short grant of self-assessment tax credit and deduction of interest on VAT duty were also restored for fresh examination. The appeal was thus partly allowed.
Transfer pricing adjustment on AMP expenditure was deleted because the Bright Line Test could not be applied to determine arm's length price, following Delhi High Court and coordinate Bench precedent; the Tribunal held no adjustment was warranted on the assessee's AMP spend. The section 43B issue on bonus payment was not decided on merits and was remitted to verify whether the bonus was paid within the return-filing due date, in which case no addition would arise. Claims relating to short grant of self-assessment tax credit and deduction of interest on VAT duty were also restored for fresh examination. The appeal was thus partly allowed.
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