S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-Corporate guarantee-Charging of guarantee fee of 0.8 Per Cent is justified-Further adjustment is not valid.[S.92CA]
Intas Pharmaceuticals Ltd. v. ACIT (2024)114 ITR 434 (Ahd)(Trib)
Digest of case laws
Online digest of latest case laws
This Digest of case laws is prepared by KSA Legal and AIFTP from judgements reported in BCAJ, CTR, DTR, ITD, ITR, ITR (Trib), Chamber's Journal, SOT, Taxman, TTJ, BCAJ, ACAJ, www.itatonline.org and other journals
Click here to download the pdf versions of the Digest of case laws S. 80P : Co-operative societies-Delay is condoned-Regular, nominal and associate members-Issue is remitted to Commissioner (Appeals).[S.80P(2)(a)(i), 143(3)]
Sahaara Alpasankyatara Vividodesha Sahakara Sangha Niyamitha v. ITO (2024)114 ITR 65 (SN)(Bang)(Trib)S. 80IC : Special category States-Gross profit from trade purchases with subsidiary not different to that from third parties-No evidence of shifting expenses to subsidiary.
Intas Pharmaceuticals Ltd. v. ACIT (2024)114 ITR 546 (Ahd)(Trib)S. 80IC : Special category States-Entire production sold to firm-Not disputing the sale price-No mistakes in books of account-No diversion of profit to firm-Denial of exemption is not justified. [S. 80IC(3)(ii), 80IE]
Intas Pharmaceuticals Ltd. v. ACIT (2024)114 ITR 434 (Ahd)(Trib)S. 80IB(10) : Housing projects-Claiming deduction in revised return-Matter remanded for reconsideration. [S. 139(1)]
ACIT v. Balaji Hotels and Enterprises Ltd. (2024)114 ITR 213 /229 TTJ 567/239 DTR 189 (Chennai)(Trib)S. 80IB: Industrial undertakings-Production of aluminium products-Allowable deduction.
Hindalco Industries Ltd. v. Dy. CIT (2024)114 ITR 502 (Mum)(Trib)S.80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Captive power plant-Supply of power to own unit-Sale of small portion to State grid corporation-Rate to be adopted-Market value-Rate at which State Electricity Board supplies to industrial consumers. [S.80IA(8)]
Hindalco Industries Ltd. v. Dy. CIT (2024)114 ITR 502 (Mum)(Trib)S. 80HHC : Export-Turnover in excess of Rs. 10 Crores-In Terms Retrospective amendment-Struck down by High Court and affirmed by Supreme Court-Substantive amendment with retrospective operation-Effective only from date of amendment.[S.80HHC(3)]
Hindalco Industries Ltd. v. Dy. CIT (2024)114 ITR 502 (Mum)(Trib)S. 69 :Unexplained investments-Alleged purchase of land-No land is purchased it was only proposal-Addition is deleted.[S. 132]
ACIT v. Jindal Poly Films Ltd. (2024)114 ITR 72 (SN)(Delhi)(Trib)S. 69 :Unexplained investments-Survey-Surrender of income-Stock offered as business income-Assessable as business income-Special rate of tax cannot be applied. [S.115BBE, 133A]
Milkhi Mal Des Raj Jain v. ACIT (2024)114 ITR 17 (Amritsar)(Trib)