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]
S. 68 : Cash credits-Inspector’s report not furnished and opportunity of cross examination not provided-Violation of principle of natural justice-Addition was deleted. [S. 131, 133(6)]
S. 56 : Income from other sources-Appellate Tribunal-Additional grounds-Shares in excess of fair market value of shares-Start-Up Companies-Consolidated circular of Central Board of Direct Taxes dealing with assessment of Start-Up Companies-Matter remanded to CIT(A). [S. 56(2)(viib), 254(1)]