Income Tax – ALP of interest on compulsorily convertible debentures determined at NIL by treating the instrument as equity - Appellant, engaged in developing and operating industrial and logistics parks, issued CCDs to its AE and paid interest thereon. The TPO treated the CCDs as instruments in the...
Income Tax – Determination of ALP of intra-group support services at NIL, Section 92C – Appellant, engaged in manufacturing and trading of household cleaning products, availed support services from two AEs in the areas of finance, human resources, marketing, business support, research and developmen...
Income Tax – Reassessment under sections 148A and 148 versus section 153C, Material found in search of third party - Petitioner challenged order under section 148A(d) and consequential notice under section 148 for Assessment Year 2016-17, issued on information received from the Investigation Wing fr...
Income Tax – Registration under Section 12AB on transition from Section 12A – Appellant, a company formed to curtail pollution generated by tannery industry, filed application in Form 10AB seeking registration under Section 12AB and the same was rejected by Ld. CIT(E) on the grounds that services ar...
Income Tax – Addition on account of cessation of liability, Section 41(1), Non-response of creditor to notice under Section 133(6) – Appellant, an individual, did not furnish any reply or documents, and the creditor also did not respond to the notice issued by the AO. The AO treated the liability in...