S. 153 : Assessment – Limitation – AO is required to pass the assessment order within the period of limitation available under S. 153(2A) of the Act. [ S.153(2A) ]
S. 153 : Assessment – Limitation – AO is required to pass the assessment order within the period of limitation available under S. 153(2A) of the Act. [ S.153(2A) ]
S. 144 : Best judgment assessment – Profit in earlier year less than in instant year – GP higher than earlier years – No addition on difference in stock found as on date of search.
S. 139 : Return-Revised return – Remanded for verification [S. 139(4)]
S. 92C : Transfer pricing – Arms’ length price – Extraordinary event occurred in the case of comparable companies is liable to be excluded. [ S.92CA ]
S. 92C : Transfer pricing – Arms’ length price – Assessee company processed, bottled and sold liquor in India under two segments Bottled in India Scotch (BIIS) and India Made Foreign Liquor (IMFL) – activities of the assessee are two different segments – assessee’s segregation approach for benchmarking these segments justified.
S. 92C : Transfer pricing -Arm’s length price- Matter was remanded .
S. 92C:Transfer pricing – Non-charging or under-charging of interest on excess period of credit allowed to AE for realization of invoices amounts to an international transaction and ALP of such an international transaction is required to be determined .
S. 80IB :Industrial undertakings – Manufacture- Conversion of 24 Karat Gold into 22 Karat Gold ornament amounts to manufacturing.[ S.2(29BA)]
S. 80IA: Industrial undertaking – Survey- Bogus purchases-Additional income offered as non genuine purchases -Entitle deduction [ S.80IA(4), 133A ,147 ]
S. 80IA : Industrial undertakings – Infrastructure Development – Joint venture between two companies Merely because assessee was paid by Government for development work, it could not be denied deduction u/s 80IA(4) when it provided a complete infrastructure required to support the development of infrastructure facility and deployed its various resources and exposed itself to various risks. [ S.80IA(3), 194C ]