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...
Penalty for failure to furnish transfer pricing documentation was deleted because the assessee had substantially complied by producing transfer pricing study reports, available segmental information and supporting documents, while the TPO accepted the benchmarking results and did not disturb the arm's length price. The alleged deficiency was only the absence of transaction-specific profitability in the form sought by the TPO, which was treated as a technical or venial breach. The Tribunal also accepted reasonable cause arising from the practical difficulty of precise AE and non-AE cost allocation in the diamond trade, and distinguished the contrary reliance on Shatrunjay Diamonds.
Penalty for failure to furnish transfer pricing documentation was deleted because the assessee had substantially complied by producing transfer pricing study reports, available segmental information and supporting documents, while the TPO accepted the benchmarking results and did not disturb the arm's length price. The alleged deficiency was only the absence of transaction-specific profitability in the form sought by the TPO, which was treated as a technical or venial breach. The Tribunal also accepted reasonable cause arising from the practical difficulty of precise AE and non-AE cost allocation in the diamond trade, and distinguished the contrary reliance on Shatrunjay Diamonds.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
