S. 154 : Rectification of mistake-Mistake apparent from the record-Business expenses-Sales promotion expenses-Debatable issue- Rectification is held to be not justified.[S. 37 (1)]
S. 154 : Rectification of mistake-Mistake apparent from the record-Business expenses-Sales promotion expenses-Debatable issue- Rectification is held to be not justified.[S. 37 (1)]
S. 147 : Reassessment-Share capital-Accommodation entry-Merely following the opinion by investigation wing-Reassessment order is quashed. [S. 68, 148, 151]
S. 145 : Method of accounting-Infrastructure development project-Project development fee received is to be apportioned over period of project-Entire fee can not be taxed during year specifically when fees apportioned to subsequent years was returned to tax by assessee in said years. [S. 4]
S. 143(3) : Assessment-Document Identification Number (DIN)-Final assessment order manually without DIN, assessment order was to be treated as never been issued.
S. 143(1) : Assessment-Intimation-Co-operative societies-Failure to file return within time prescribed under section 139(1)-Claim of deduction under section 80P could not be denied by making prima facie adjustment.[S.80P, 139(1), 143(1)(a)(v)]
S. 143(1) : Assessment-Intimation-Expenses or payments not deductible-Payment to Government-Cash payments exceeding prescribed limits-Payment towards purchase of liquor to a State Government undertaking-CPC Bengaluru would have either accepted said explanation or rejected after giving cogent reasons. [S.40A(3), 143(1)(a), R.6DD]
S. 143(1) : Assessment-Intimation-Club membership fee-Auditor has not qualified-Adjustment is not justified. [S. 37(1), 143(1)(a)]
S. 115JAA : Company-Book profit-Deemed income-Tax credit-Companies-Surcharge and cess- Irrespective of variation in its rate subsequently, would stand to be paid only for year for which tax is payable under regular provisions of Act, i.e., at an amount net of tax credit, and at rate applicable for that year-No question of set off of surcharge/cess, as in case of tax, in absence of specific provisions in its respect. [S. 4, 115JB]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Contracts with third party customers-Tested parties-Difference in margin rate falls within tolerance limit of 5 per cent, in which case, international transactions of assessee should be considered to be at arms length-Adjustment is deleted-Delay in receiving money-Interest was to be computed individually after allowing accepted credit period-Matter remanded.
S. 80P : Co-operative societies-Interest income from investments made in various Co-operative Banks-Entitle to deduction. [S. 80P(2)(d), 80P(4)]