S. 263 : Commissioner-Revision of orders prejudicial to revenue-Transfer pricing adjustment-Failure by Assessing Officer to make assessment in conformity with order of Transfer Pricing Officer-Revision is valid. [S. 92CA]
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Transfer pricing adjustment-Failure by Assessing Officer to make assessment in conformity with order of Transfer Pricing Officer-Revision is valid. [S. 92CA]
S. 234E : Fee-Default in furnishing the statements-Statements of tax deducted at source-Levy of fees for Assessment Years 2013-14, 2014-15 and 2015-16 not justified-CIT (A) erred in not condoning the delay. [S. 200A, 250]
S. 198 : Deduction at source-Tax deducted is income received-Credit for tax deducted-Refund-Duty of Assessing Officer to allow credit-Rejection of claim to refund treating letters as barred by limitation-Held to be not proper-Directed the Assessing Officer to allow credit and grant consequential refund. [S. 154(7), 199, 26AS]
S. 153A : Assessment-Search or requisition-No incriminating documents found-No assessment was pending-long term capital gains-Addition is not justified. [S. 45, 143(3)]
S. 147 : Reassessment-Accommodation entries-Information from Investigation wing-Name of assessee was not appearing in statement-Reopening is bad in law. [S. 148]
S. 147 : Reassessment-After the expiry of four years–Depreciation-Granted on Bridge at rate applicable to building instead of rate applicable to plant and machinery-Reassessment valid-Direction of CIT(A) to allow amortization of expenditure incurred during tenure of agreement is justified. [S. 32(1)(ii), 37(1), 143(3), 148]
S. 145 : Method of accounting-Developer-Mercantile system of accounting-Completion project-Deletion of additions on account of estimation of work-in-progress is justified.
S. 139 : Return of income-Return of loss-Non-Resident company-Return of loss filed beyond due date-Not eligible to carry forward losses. [S. 139(1)]
S. 133A : Power of survey-Statement during survey-Addition cannot be made merely on the basis of statement in the course of survey without bringing any corroborative evidence on record-CBDT Instructions F. No. 286/2/2003-It (Inv), Dated 10-3-2003 and F. No. 286/98/2013-It (Inv. Ii), Dated 18-12-2014. [S. 119]
S. 92C : Transfer pricing-Arm’s length price-Purchase of sap licence-Details submitted but authorities failing to consider-Application of benefit test instead of methodology set out in Act and rules not sustainable. [R. 10B]