Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Transfer pricing disputes over intra-group services, the sensor assembling segment and business support services were restored for fresh adjudication because the assessee sought to place additional evidence and the Tribunal found reconsideration necessary. The intra-group services adjustment was remitted to the AO/TPO for fresh decision after due opportunity. The choice between the Resale Price Method and the Transactional Net Margin Method for the sensor assembling segment was left open for reconsideration, and the comparables, filter changes and denied risk adjustment in business support services were also remitted. The assessment order was set aside to that extent and the appeal was partly allowed for statistical purposes.
Transfer pricing disputes over intra-group services, the sensor assembling segment and business support services were restored for fresh adjudication because the assessee sought to place additional evidence and the Tribunal found reconsideration necessary. The intra-group services adjustment was remitted to the AO/TPO for fresh decision after due opportunity. The choice between the Resale Price Method and the Transactional Net Margin Method for the sensor assembling segment was left open for reconsideration, and the comparables, filter changes and denied risk adjustment in business support services were also remitted. The assessment order was set aside to that extent and the appeal was partly allowed for statistical purposes.
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