S. 115BAA: Certain domestic companies, tax on-Revised return filed after the due date of filing of return was not entertained-SLP of assessee was dismissed.[S. 115JB, 139, Form 10-IC, Art. 136]
S. 115BAA: Certain domestic companies, tax on-Revised return filed after the due date of filing of return was not entertained-SLP of assessee was dismissed.[S. 115JB, 139, Form 10-IC, Art. 136]
S. 92C: Transfer pricing-Arm’s length price-Distribution business-No ALP adjustment made by TPO-Separate AMP adjustment was uncalled for-Order of Tribunal affirmed. [S. 260A ]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Intra-group services-Matter remanded by Tribunal to Transfer Pricing Officer-High Court holding no infirmity in order of Tribunal-SLP of revenue dismissed.[S.92CA(3), Art. 136]
S. 80IB(10): Housing projects-Built up area of each flat less than 1000 square feet-Approved construction plan-Unexplained money-Three flats on the same floor were sold at different rates-Rates at which flats were sold were higher than stamp valuation-Order of Tribunal deleting the addition was affirmed-No question of law. [S.69A, 260A]
S. 69C: Unexplained expenditure-Bogus purchases-Information for sales tax department-Hawala transactions-Not given an opportunity of cross-examination-Order of Tribunal limiting addition to 15 per cent of alleged purchases was affirmed. [S. 260A]
S. 68: Cash credits-Share application money-Shell company-Mere production of incorporation certificates, PAN numbers, income tax returns, or showing that transactions were routed through banking channels could not discharge the burden of proof under section 68-Assessing Officer’s conclusion was founded upon tangible, cogent and independent evidence, and not on conjecture, addition made by Assessing Officer was justified-Order of Tribunal set side. [S. 260A]
S. 68 : Cash credits-Penny stock-Sun Rise Asian Ltd (SAL)-Long-term capital gains-Order of Tribunal deleting the addition is affirmed.[S. 10(38), 45]
S. 67A: Association of persons-Body of individuals-Member’s share-Member of syndicates engaged in liquor business-Share of assessee in income of syndicate-Not taxable when association of persons taxed at maximum marginal rate-SLP of revenue dismissed. [S.2(31),86, 167B, Art. 136]
S. 37(1): Business expenditure-Expenditure debited in the profit and loss account was not claimed as a deduction-Disallowance made by the Assessing Officer is held to be unsustainable-Order quashed. [S. 10(23FBA), 115UB, 143(3), Art.226]
S. 37(1): Business expenditure-Provision for discount-Order of Tribunal allowing the claim is affirmed. [S.260A]