Since AO has not conclusively proved the fact that there is an ...

Case Laws Income Tax

July 27, 2015

Since AO has not conclusively proved the fact that there is an arrangement between assessee and its AE by which the transactions were so arranged as to produce more than the ordinary profits in the hands of assessee, disallowance of part deduction claimed by applying the provisions of section 80IA(10), in our view is not justified - AT

View Source

← Previous Next →

Since AO has not conclusively proved the fact that there is an ...

Case Laws Income Tax

July 27, 2015

You may also like:

Deduction u/s 10B - ordinarily, what profit the assessee might have expected to arise - AO had not brought on record any material to demonstrate that the assessee...

Bogus LTCG - genuineness of transaction not proved - exemption u/s 10(38) - assessee failed to prove genuineness of transaction and long-term capital gain on sale of...

TDS u/s 195 - software expenses - the arrangement of the assessee company with its AE is of purchase of computer software at agreed price i.e. sale price to the Indian...

Deletion of LTCG as non-genuine - transactions in shares - Deletion of undisclosed commission paid for arranging accommodation entries - assessee proves that...

TP adjustment on account of reimbursement of seafarer expenses - Revenue has only doubted the genuineness of the alleged reimbursement of expenses made by the assessee...

Penalty levied u/s 271(1)(c) - Transfer pricing adjustment - assessee advanced interest free loan to its AE - The Tribunal noted that the assessee had disclosed all...

Bogus transaction in the scrip - bogus LTCG - Onus to prove - Income generated by the assessee cannot be held bogus only on the basis of the modus operandi,...

Addition u/s 68 - unexplained cash credits - Onus to prove - CIT(A) deleted addition - The Tribunal found that the assessee failed to discharge its onus of proving the...

TP Adjustment - existence of international transaction of AMP Expenses - the revenue has also substantially proved the onus of existence of international transaction...

Transfer pricing adjustment – Indenting transactions - commission percentage from AE transactions should be benchmarked on the basis of commission rate from non-AE...

Bogus purchases - addition made towards entire bogus purchase - Assessee has literally wasted precious time of the AO by once again issuing notices and summons to the...

Set-off of capital loss - The assessee states that it be the ultimate holding company was obligated to support its subsidiary companies likes RCML to revive their...

Onus to prove – the revenue has to prove the existence of a fact that undervaluation of asset was made by the assessee - When that fact is proved, the burden shifts to...

TP adjustment made in respect of provision of back office services - In any case, we find the main grievance of the ld. DRP seems to be that AE revenue is only ₹...

Dishonour of Cheque - rebuttal the presumption - existence of legally enforceable debt or not - Facts is of two kinds. One is positive fact and another is negative fact....

Quick Updates: