Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Deductibility of settlement payments for securities law penalties and treatment of unexplained cash credits in share trading -- Tribunal upholds posit...
Threshold for allottee-initiated insolvency petitions in leasehold real estate upheld; petition admitted after possession letters deemed legally ineff...
Contravention of foreign exchange rules in crossborder diamond payments; appellate tribunal reduces one appellant's penalty for delay and proportional...
Transfer pricing comparables were revisited because the stated related party transaction filter exclusions were not supported by the record. The exclusion of I Services India Private Limited required verification of available financial details and fresh computation of the related party transaction percentage before reconsidering inclusion. The exclusion of Cheers Interactive India Private Limited also required recomputation, after excluding payments to key managerial personnel in India from the related party transaction filter, before deciding comparability. On the corporate tax issue, the alleged disallowance of interest on TDS appeared to have been added twice in processing the return, so the Assessing Officer was directed to verify duplication and delete any double addition if established.
Transfer pricing comparables were revisited because the stated related party transaction filter exclusions were not supported by the record. The exclusion of I Services India Private Limited required verification of available financial details and fresh computation of the related party transaction percentage before reconsidering inclusion. The exclusion of Cheers Interactive India Private Limited also required recomputation, after excluding payments to key managerial personnel in India from the related party transaction filter, before deciding comparability. On the corporate tax issue, the alleged disallowance of interest on TDS appeared to have been added twice in processing the return, so the Assessing Officer was directed to verify duplication and delete any double addition if established.
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