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Suraj R. Agrawal

Latest Posts by Suraj R. Agrawal

A comprehensive analysis of function of electronic information in tax assessments

August 7, 2024 999 Views 0 comment Print

Explore how electronic data transforms tax assessments, highlighting accuracy issues, verification needs, and taxpayer rights as seen in the Benaifer Vispi Patel case.

Comprehensive Overview of Key Tax Amendments in Finance Bill 2024

July 23, 2024 1818 Views 0 comment Print

Explore the Finance Act 2024 amendments impacting income tax rates, TDS, capital gains, and more. Stay informed on key changes affecting businesses and individuals.

Tax Avoidance and Invocation of GAAR: Case of Ayodhya Rami Reddy Alla

June 11, 2024 3177 Views 1 comment Print

Explore the Ayodhya Rami Reddy Alla vs PCIT case, delving into GAAR vs SAAR implications. Understand the Telangana High Court’s ruling on tax avoidance and the invocation of GAAR.

ITAT Rulings on TP Adjustments, ESOP Expenses & Section 14A Disallowance

June 11, 2024 465 Views 0 comment Print

Tribunal upholds CIT(A) decisions in DCIT Vs Astral Limited case, offering key insights on TP adjustments, ESOP expenses, and Section 14A disallowance.

No Section 56(2)(viib) on Loan Conversion to Equity; Choice of Valuation Method with Assessee, not AO

June 7, 2024 1464 Views 0 comment Print

Explore the implications of the PCIT Vs I.A. Hydro Energy case regarding loan conversion to equity under Section 56(2)(viib) of the Income Tax Act, 1961, highlighting the choice of valuation method with the assessee.

Carry Forward & Set Off of Losses in Case of Closely Held Companies [Section 79]

June 15, 2022 5589 Views 0 comment Print

Learn about carry forward and set off of losses in case of closely held companies under Section 79. Understand the conditions for carrying forward losses and make informed financial decisions.

Carry Forward & Set Off of Accumulated Business Losses and Unabsorbed Depreciation in Certain Cases

June 13, 2022 22200 Views 0 comment Print

Carry Forward and Set Off of Accumulated Business Losses and Unabsorbed Depreciation in Certain Cases of Amalgamation, Demerger, Re-organisation of business & Conversion of a company into LLP

Powers/Jurisdiction of Assessing Authorities for Reassessment u/s 147

July 21, 2021 2343 Views 0 comment Print

Aban Offshore Limited Vs Addl. CIT (Madras High Court) Case Summary: – Facts of the case: ♦ The Assessee, Aban Offshore Limited, engaged in providing oil field services to various oil majors for offshore exploration and production of hydrocarbons in India and abroad, is a regular Assessee in terms of the provisions of the Indian […]

Section 56(2)(v) relative definition not apply for Specified Domestic Transactions

July 14, 2021 3912 Views 0 comment Print

Smt. Anita Sunil Mahajan Vs ACIT (ITAT Pune) Definition of ‘relative’ for Specified Domestic Transactions (SDTs) should be as per Section 2(41) of Income Tax Act, 1961 and Section 56(2)(v) would not apply. Case Summary: – Facts of the case: During AY 2013-14, Smt. Anita Sunil Mahajan (Assessee), filed her return declaring total income at […]

What is International Transaction for Transfer Pricing?

June 15, 2021 6078 Views 0 comment Print

Section 92 of the Income Tax Act deals with any income or expense arising from an ‘International Transaction’. In order to understand the definition of ‘International Transaction’, it is essential to understand the definition of ‘Transaction’. Clause (v) of Sections 92F of the Act defines a transaction as: Section 92F of the Act provides an […]

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