Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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Transfer pricing adjustments on intra-group management charges were deleted after accepting the assessee's TNMM benchmarking and rejecting a nil arm's length value. Royalty on sales was restricted by allowing 5% on both sales to associated enterprises and third parties, as the authorities could not disallow the entire payment or treat the assessee as a contract manufacturer for this purpose. For outstanding receivables, working capital adjustment had to be given first; only any remaining shortfall could be examined again for interest adjustment, so the issue was restored for fresh determination. Disallowance of employees' PF and ESI contribution deposited after the welfare law due date was sustained, as later payment within the income-tax filing timeline did not cure the default.
Transfer pricing adjustments on intra-group management charges were deleted after accepting the assessee's TNMM benchmarking and rejecting a nil arm's length value. Royalty on sales was restricted by allowing 5% on both sales to associated enterprises and third parties, as the authorities could not disallow the entire payment or treat the assessee as a contract manufacturer for this purpose. For outstanding receivables, working capital adjustment had to be given first; only any remaining shortfall could be examined again for interest adjustment, so the issue was restored for fresh determination. Disallowance of employees' PF and ESI contribution deposited after the welfare law due date was sustained, as later payment within the income-tax filing timeline did not cure the default.
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