S. 147 : Reassessment – Change of opinion- Loans or advances to share holders – Disclosed material facts- Reassessment is held to be not valid. [S.2(22)(e), 148 ]
S. 147 : Reassessment – Change of opinion- Loans or advances to share holders – Disclosed material facts- Reassessment is held to be not valid. [S.2(22)(e), 148 ]
S. 147 : Reassessment–With in four years-Cash credits–Bogus accommodation entries- sums were received in earlier assessment year 2010-11 and were already verified and assessed by revenue authorities- Reopening of assessment in current assessment year is held to be not valid. [S. 68, 133, 148].
S. 147 : Reassessment–Deemed dividend-Audit information-Loan from company-loan transaction was duly scrutinized by Assessing Officer in original assessment-Notice was issued on insistence of audit party- Reassessment is held to be bad in law. [S.2(22)(e), 148]
S. 147 : Reassessment–Audit objection-Business expenditure–Forex gain-merely on the basis of audit objection–Reassessment is not valid [ S.37(1), 148]
S. 145 : Method of accounting–Undervaluation of sales and estimation of gross profit–Deletion of addition is held to be justified.
S. 115V-I : Shipping business – Shipping income -Tonnage tax scheme-Forex rate fluctuation gains -Gains on account of exchange rate variations of foreign loan taken for purchase of ships being connected to assessee’s core activities of operating qualifying ships would be entitled to benefit under Chapter XII-G.
S. 92C : Transfer pricing–Arm’s length price-Company which outsources its work is not comparable for ALP determination with a company that does activity inhouse-A company having substantial related party transactions, could not be selected as comparable.
S. 80IA : Industrial undertakings-Net interest excluding expenditure incurred in earning such interest income which had to be excluded for purpose of computing deduction.
S. 74 : Losses – Capital gains – Carry forward – Advance Rulings- Loss determined in pursuance of a return filed for earlier assessment u/s 139 can only be carried forward. – Only party before the authority can be heard – Other parties cannot be heard by Court . [ S. 80 , 139(3), 245N, Art . 226 ]
S. 69A : Unexplained money – Search and seizure-illegal capitation fees –Addition on estimate basis is held to be justified.