S. 147 : Reassessment-After the expiry of four years-No failure To Disclose material facts-Reassessment not valid. [S. 148]
S. 147 : Reassessment-After the expiry of four years-No failure To Disclose material facts-Reassessment not valid. [S. 148]
S. 145 : Method of accounting-Non maintenance of stock register can be the ground to reject the books of account. [S. 145(3)]
S. 143(3) : Assessment-Deduction not claimed in return but later by letter to Assessing Officer during assessment proceedings-Appellate Authority Can Consider-Foreign exchange loss-Loss pertaining to current year lone is allowable. [S. 28(i), 139, Art. 265]
S. 143(3) : Assessment-Bogus purchases-Sales not doubted-Purchases to be treated as genuine. [145 (3)]
S. 143(3) : Assessment-Income from undisclosed sources-Ad hoc addition basis of third party information-Matter remanded to the Assessing Officer. [S. 194J]
S. 143(3) : Assessment-Amalgamation-Assessment order made in name of amalgamating company-Entity non-existent on date of passing of order-Order null and void.
S. 92C : Transfer pricing-Arm’s length price-Comparable-Having vastly higher turnover cannot be used-Amalgamation not reason For exclusion-Income-tax Authorities-Transfer Pricing Officer-Include additional Commissioner-Order passed by Additional Commissioner is valid. [S. 2(28C), 92CA, 117(1)]
S. 92C : Transfer pricing-Arm’s length price-Comparable-Loss making companies to be excluded-High margin cannot be excluded unless backed by certain extraordinary events-Risk adjustment to be considered-Adjustment to be worked out applying average profit level indicator of comparables to cost of international transactions and not on its sale turnover.
S. 92C : Transfer pricing-Arm’s length price-Interest receivable from associate enterprise for delay in payment-Addition is not justified when requisite adjustment made to working capital.
S. 80P : Co-operative societies-Return filed in response to notice under section 148-Deduction cannot be denied-Interest earned from funds belonging to members-Deduction allowable. [S. 80A(5), 80P(2)(a)(i), 147, 148]