S. 144B : Faceless Assessment-Reassessment-Alternative remedy-Question of fact-Writ petition is dismissed-Directed to file statutory appeal.[S. 69C,115BBE, 147, 148,246A, Art.226
S. 144B : Faceless Assessment-Reassessment-Alternative remedy-Question of fact-Writ petition is dismissed-Directed to file statutory appeal.[S. 69C,115BBE, 147, 148,246A, Art.226
S. 143(3) : Assessment-Income-Tax Authorities-High Court-Binding precedent-Decision of High Court is binding on Income-Tax Authorities-Order of Assessment ignoring direction of High Court is not valid [S. 56(2)(viib), Art. 215, 226, 227]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Net margin method-Identical with earlier years-No substantial question of law. [S.260A]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Exclusion of companies large and with functional and segmental dissimilarities-Appreciation of facts-No substantial question of law.[S.92CA(3), 260A]
S. 68 : Cash credits-Share capital-Ready to submit relevant documents-Matter remanded to Assessing Officer for fresh consideration. [S. 260A]
S. 68 : Cash credits-Proved genuineness of transactions-Order of Tribunal deleting the addition is affirmed. [S. 260A]
S. 50B : Capital gains-Slump sale-Sale of business as running concern —Sale is not of itemised assets-Transfer of goodwill and know-how did not give rise to capital gains as no cost of acquisition ascertainable-Not liable to tax. [S. 2(42C), 41(2), 45, 50(2), 50B(2) 55(2)(a), 260A]
S. 50B : Capital gains-Slump sale-Sale of business as running concern-Sale is not of itemised assets-Not liable to tax-SLP of Revenue is dismissed. [S. 2(42C), 41(2), 45, 50(2), 50B(2) 55(2)(a), Art. 136]
S. 37(1): Business expenditure-Capital or revenue – Purchase of software – Not necessary that income must be earned because of such expenditure.[S. 28(i)]
S. 12AB: Procedure for fresh registration Cancellation of registration with retrospective effect-On writ filed by the petitioner, the Court granted the interim stay-SLP of Revenue is dismissed. [S. 12A, 12AA, 12AB(4), Art. 136]