S. 144B : Faceless Assessment-Principle of Natural justice is violated-Cash credits-Order was passed without giving an opportunity of hearing-Order was set aside. [S. 68, 142(1), 143(3), Art. 226]
S. 144B : Faceless Assessment-Principle of Natural justice is violated-Cash credits-Order was passed without giving an opportunity of hearing-Order was set aside. [S. 68, 142(1), 143(3), Art. 226]
S. 144B : Faceless Assessment-Principle of Natural justice is violated-Cash credits-Order was passed without giving an opportunity of hearing-Order was set aside. [S. 68, 142(1), 143(3), Art. 226]
S. 143(3) : Assessment-Cash credits-Natural justice-COVID-19-Failure to grant reasonable opportunity for furnishing details-Assessment order was set aside. [S. 68, 132 Art. 226]
S. 132B : Application of seized or requisitioned assets-Jewellery seized-Failure to pass an order within period of 120 days on which last authorisation of search was executed-Entire jewellery seized was directed to be released. [S. 132, Art. 226]
S. 132(4) : Search and seizure-Statement on oath-Undisclosed income-Retraction-Failure to produce any evidence contrary to the statement-Order of Tribunal is affirmed. [S. 132]
S. 92C : Transfer pricing-Arm’s length price-Functionally different-Justified in directing for exclusion of ABCL from the list of comparables-Interest receivable-Notional interest for relating to alleged delayed in collecting receivable-No substantial question of law-Question as to whether in a given case transfer pricing adjustment on delayed receivable could apply even to a debt-free company or not. does not arise on facts and is left open. [S. 260A]
S. 92C : Transfer pricing-Arm’s length price-TNM method-Transaction of buying services for sourcing garments in India-Addition made to ALP by applying cost plus 5 per cent mark-up on FOB value of exports among third parties was not supported under rule 10B(1)(e) and was liable to be deleted. [R. 10B(1)(e)]
S. 69C : Unexplained expenditure-Failure to explain the source-Justified in confirming the disallowance.
S. 68 : Cash credits-Share application money-Shell companies-Share holders could not explain their source-Addition is held to be justified.
S. 48 : Capital gains-Computation-Full value of consideration-Retention of money in Escrow account-Possession was handed over-Amount of money in Escrow account has to be considered while computing the capital gain for the purpose of full consideration. [S. 45]