S. 14A : Disallowance of expenditure-Exempt income-No expenditure was incurred directly or indirectly-No disallowance can be made.
S. 14A : Disallowance of expenditure-Exempt income-No expenditure was incurred directly or indirectly-No disallowance can be made.
S. 12AA : Procedure for registration-Trust or institution-First application was pending-Second application was filed-Retrospective registration could not be granted based on the first application. [Rule, 17A, Form No. 10A]
S. 10A : Free trade zone-Export turnover-Total turnover-Expenses incurred by in foreign currency was to be excluded from both export turnover and total turnover for computation of deduction.
S. 10(23C) : Educational institution-Exemption cannot be denied on ground that it does not have independent Memorandum of Association, Bye laws, etc. [S. 10 (23)(vi)]
The Direct Tax Vivad Se Vishwas Act, 2020.
S. 4 : Filing of declaration and particulars to be furnished – – Withdrawal application is allowed – Given liberty to restore this appeal in event ultimate decision to be taken on declaration filed by assessee under section 4 was not in favour of assessee . [ S.254 (1)
The Direct Tax Vivad Se Vishwas Act, 2020.
S. 4 : Filing of declaration and particulars to be furnished – Remand of matter – Withdrawal application is allowed – Given liberty to restore this appeal in event ultimate decision to be taken on declaration filed by assessee under section 4 was not in favour of assessee
Direct Tax Vivad Se Vishwas Act, 2020
S. 4 : Filing of declaration and particulars to be furnished – Withdrawal application is allowed – Given liberty to restore this appeal in event ultimate decision to be taken on declaration filed by assessee under section 4 was not in favour of assessee [ S. 54F ]
S. 147 : Reassessment – Book profit – No failure to disclose material facts – With in four years – Change of opinion – Reassessment is held to be bad in law . [ S.14A, 115JB , 148 ]
S. 271G : Penalty – Documents – International transaction – Transfer pricing –Failure to maintain documents – Levy of penalty is held to be not justified . [92C(1), 92CA, 92D, 92D(1)]
S. 271(1)(c) : Penalty – Concealment – Failure to deduct tax at source – Transfer pricing adjustments- Explanation 7- Deletion of penalty is held to be justified . [ S.92C ]