1

Commissioner (A) is not empowered to enhance income a new source of income vide 82ITR 9Trib) 176
1

It is assessee’s choice to select a method for determining FMV of shares vide 81 ITR (Trib) (SN) 78
1

No TP adjustment of trade receivables in case of a debt-free company vide 81ITR (Trib) (SN) 94
1

To accord registration as a charitable institution under income tax dominant purpose must be charitable and satisfies the conditions laid down us 2(15) vide 426ITR108 despite having non charitable ancillary objects meant to achieve the dominant purpose
1

Transactions with dubious entities is reason enough for case reopening vide 421ITR624

rule 28AA is a bible to lower rate applications

ByCA Gopal Nathani

Jun 28, 2022

The Delhi High Court ruling in (2022) 443ITR441 emphasised the importance of rule 28AA and denounced action of the AO in stepping out of rule 28AA and denying benefit of DTAA and insisted for 10% TDS on receipt of aircraft lease rentals by Ireland based aircraft leasing company. In the past nil certificates were issued.

In this case there had been a survey action and reopening of group companies of the applicant which overturned the view held earlier on the premise that survey action may fasten demand even upon the assessee.