Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Appellate proceedings cannot be used to introduce a new head of income or enhance an assessment without following the prescribed procedure. Where the original dispute concerned only denial of deduction under section 54F on the basis of alleged multiple residential units and a claimed sham transfer, and the appellate authority accepted that the transfer was lawful, that controversy stood concluded. The further step of taxing the share-sale consideration under section 56 amounted to an unauthorised enhancement and a change in the basis of assessment. The appellate order was therefore unsustainable, and the deduction under section 54F was directed to be allowed.
Appellate proceedings cannot be used to introduce a new head of income or enhance an assessment without following the prescribed procedure. Where the original dispute concerned only denial of deduction under section 54F on the basis of alleged multiple residential units and a claimed sham transfer, and the appellate authority accepted that the transfer was lawful, that controversy stood concluded. The further step of taxing the share-sale consideration under section 56 amounted to an unauthorised enhancement and a change in the basis of assessment. The appellate order was therefore unsustainable, and the deduction under section 54F was directed to be allowed.
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