S. 153B : Assessment – Search – Time limit – On a remand under S. 263, such assessment would have to be completed only within a reasonable period of time. [ S.153A, 263 ]
S. 153B : Assessment – Search – Time limit – On a remand under S. 263, such assessment would have to be completed only within a reasonable period of time. [ S.153A, 263 ]
S.147: Reassessment -Share capital- Bogus accommodation entries – Reassessment was held to be valid [ S. 68 ,143(1),148 ]
S.147: Reassessment-After the expiry of four years- Firm -Partner- Pension paid to retiring partner which was allowed as deduction- Reassessment was held to be not valid [ S. 37(1),148 , 184 ]
S. 145 : Method of accounting – Mere fact that books of account were not supported by vouchers of payments received from patients, same could not be a ground to reject assessee’s books of account and to make addition on estimate basis
S. 139AA: Return of income – Quoting of Aadhaar Number – Compulsory for assessees to give their Aadhaar Number while filing their income tax return.
S.139: Return- Delay in filing of return- Reasonable cause- Court directed the CBDT to reconsider the application for condonation of delay as the as the circumstances were beyond the control of the assessee. [ S.80AC, 80IB, 119 ]
S.92C: Transfer pricing- Any inclusion or exclusion of comparables per se cannot be treated as a question of law unless it is demonstrated that the Tribunal has taken in to irrelevant consideration .[ S.260A]
S.92C: Transfer pricing- Broad threshold figure of 25 per cent RPT in case of comparables is essential- Brand does play its own role in price or cost determination and, they would not be comparable to each other
CIT v. Dilip Singh. (2018) 253 Taxman 41 / 300 CTR 184 /161 DTR 97 (Cal)(HC)
S. 92B : Transfer pricing – International transaction- Royalty arising out of use of brand name had to be treated as an international transaction.[ S.92C ]
S. 69B : Amounts of investments not fully disclosed in books of account –Receipts of jewellery in the name of assessee which was found in the course of search was from the disclosed income of the wife accordingly deletion of addition was held to be justified [ S.132B, 158B, 292C ]