Income Tax - General Anti-Avoidance Rule - Existence of an arrangement under Section 102(1) in purchase of pre-bonus shares and sale of equivalent quantity post-bonus on a recognised stock exchange - Petitioner, successor in business of a company that transferred its undertaking as a going concern u...
Income Tax – Validity of show-cause notice under Section 148A(1), Limitation under Section 149(2)(b), Applicability of Section 56(2)(x) to proportionate rights allotment of shares - Petitioner subscribed to rights equity shares, and the AO issued a show-cause notice for Assessment Year 2020-21 withi...
Income Tax – Residual Profit Split Method accepted as most appropriate method, Additional entity-level margin adjustment, Section 92C read with Rule 10C, Corporate guarantee, Interest saving approach versus bank guarantee rates – Appellant is engaged in providing data analytics and related IT-enable...
Income Tax - Comparability adjustment for extraordinary under-utilisation of capacity during COVID-19 year, Rule 10B(3) – Appellant, a subsidiary of its holding company, rendered software consultancy and support services to its AE and adopted TNMM with OP/OC as PLI, and in its TP study report create...
Income Tax – Taxability of interest earned on funds advanced by Government, Signature bonus received on transfer of power projects, Revenue or capital receipt – Appellant company was promoted by the Electricity Board and Government to augment power generating capacity, and the AO added interest inco...