Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
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Reassessment based on Investigation Wing information was sustained where the original return had only been processed under section 143(1), no return was filed in response to notice under section 148, and the recorded reasons showed a live link between identified penny stock transactions and the belief of escapement. The Tribunal held that the assessee could not invoke the procedural objections available after filing a return in response to reopening, and the challenge to jurisdiction failed. On the merits, the section 68 addition on share sale proceeds was deleted because the transactions were disclosed as part of regular share trading business, supported by contract notes, demat and bank records, and no exempt long-term capital gains had been claimed.
Reassessment based on Investigation Wing information was sustained where the original return had only been processed under section 143(1), no return was filed in response to notice under section 148, and the recorded reasons showed a live link between identified penny stock transactions and the belief of escapement. The Tribunal held that the assessee could not invoke the procedural objections available after filing a return in response to reopening, and the challenge to jurisdiction failed. On the merits, the section 68 addition on share sale proceeds was deleted because the transactions were disclosed as part of regular share trading business, supported by contract notes, demat and bank records, and no exempt long-term capital gains had been claimed.
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