Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
The ITAT found that the addition relating to alleged immovable property transactions was made without proper verification of the basic facts, particularly because the assessment record showed inconsistency in how the same properties were treated and the AO had shifted between possible taxability under section 56(2)(x) and section 50C. The Tribunal noted that no addition was ultimately made under section 56(2)(x), while the section 50C addition rested on an unverified factual foundation, and the assessee's cancellation claim was unsupported by the record. The matter was therefore restored to the jurisdictional AO for fresh examination and re-adjudication on evidence and enquiry.
The ITAT found that the addition relating to alleged immovable property transactions was made without proper verification of the basic facts, particularly because the assessment record showed inconsistency in how the same properties were treated and the AO had shifted between possible taxability under section 56(2)(x) and section 50C. The Tribunal noted that no addition was ultimately made under section 56(2)(x), while the section 50C addition rested on an unverified factual foundation, and the assessee's cancellation claim was unsupported by the record. The matter was therefore restored to the jurisdictional AO for fresh examination and re-adjudication on evidence and enquiry.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4809 
Join Channel 
