S. 147 : Reassessment-Cash deposits-Search-Salary-Investigation-Reassessment is valid-Unexplained cash-Source is not explained-Addition is affirmed. [S.68,69A, 132, 148]
S. 147 : Reassessment-Cash deposits-Search-Salary-Investigation-Reassessment is valid-Unexplained cash-Source is not explained-Addition is affirmed. [S.68,69A, 132, 148]
S. 147: Reassessment-Cash deposit-No mentioning of name of asseessee in Investigation report-Objection not fully disposed of-Reassessment is quashed. [S.68,133(6), 148]
S. 147 : Reassessment-Non application of mind-Shell companies-Web site of the Income-tax portal-Re produced information without cross verification-The reopening of assessment is quashed.[S. 148]
S. 145 : Method of accounting-Failure to produce details-Rejection of books of account is justified-Matter is restored back to the AO to estimate the profit of the assessee at a percentage worked out on the basis of preceding three years. [S. 145(3)]
S. 143(3): Assessment-Limited scrutiny-Interest income mismatch-Without following the prescribed procedure and necessary approval of the competent authority conducting an enquiry on the issue which is outside the limited scrutiny would be beyond the jurisdiction of the AO-The Assessment order is quashed. [S. 143(2)]
S. 143(3): Assessment-Jurisdiction-Income include loss-Corporate assessee-Jurisdiction was with ACIT/Dy. CIT-The assessee had disclosed loss of Rs. 3,29,55,888-Notice is valid-Rejection of books of account is justified-Estimate of 10 percent of net profit is reasonable. [S. 2(24), 120, 143(2), 145(2)]
S. 143(2) : Assessment-Notice-Shifting of residence from Delhi to Gurgaon-Change is reflected in the return filed-Notice issued by the Assessing Officer from Delhi is without jurisdiction-Quashed-Additional ground-Jurisdictional issue-Admitted [S. 254(1)]
S. 143(1) : Assessment-Intimation-Failure to file Form No 10B-Adjustment is justified-Disallowance of expenditure-Revenue is directed to intimate the exact reason for disallowing the claim of the assessee while processing the return-The assessee may file an application under S. 154 to rectify the mistake in the intimation, as deemed proper-Assessee is also free to avail the remedy under s. 119 if it so desires. [S. 10(23C), 11, 119, 154, 250(5)]
S. 143(1) : Assessment-Intimation-Prima facie adjustment-under late payment of employees’ contribution towards PF and ESI-Adjustment is valid-Not allowable as deduction. [S.36(1(va), 37(1), 143(1)(a)]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-comparables-There is no error in the reasons given by the TPO/DRP to include L&T in the final set of comparables-PLR-Interest on outstanding receivable-TPO is directed to adopt appropriate rate of interest by considering the currency in which the outstanding receivable by the assessee and its AE. [S.92B]