Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Transfer pricing adjustment on intra-group services was deleted because the Tribunal followed binding decisions in the assessee's own earlier years, affirmed by the Gujarat High Court, holding that actual receipt of services and business nexus had been demonstrated. It accepted that the TPO could not fix arm's length price at nil merely on perceived lack of benefit, duplication, or shareholder characterisation, and that an ALP determination requires application of a prescribed benchmarking method with comparable uncontrolled analysis. The grounds challenging the validity of assessment were dismissed as not pressed, and the appeal was partly allowed.
Transfer pricing adjustment on intra-group services was deleted because the Tribunal followed binding decisions in the assessee's own earlier years, affirmed by the Gujarat High Court, holding that actual receipt of services and business nexus had been demonstrated. It accepted that the TPO could not fix arm's length price at nil merely on perceived lack of benefit, duplication, or shareholder characterisation, and that an ALP determination requires application of a prescribed benchmarking method with comparable uncontrolled analysis. The grounds challenging the validity of assessment were dismissed as not pressed, and the appeal was partly allowed.
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