Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
For exempt-income disallowance under Rule 8D, only investments that actually yielded exempt income were to be considered, and the matter was remitted for recomputation. Notional interest on business advances was deleted because there was no actual accrual or receipt and the advances were not shown to be lending transactions. In transfer pricing, foreign currency loans repayable in US dollars were to be benchmarked by reference to LIBOR, not the domestic lending rate, while TNMM for AE sales was upheld and excluded comparables were sustained. A separate adjustment on outstanding receivables was rejected where working-capital effects were already reflected. The section 14A amount was also not added to book profit under MAT.
For exempt-income disallowance under Rule 8D, only investments that actually yielded exempt income were to be considered, and the matter was remitted for recomputation. Notional interest on business advances was deleted because there was no actual accrual or receipt and the advances were not shown to be lending transactions. In transfer pricing, foreign currency loans repayable in US dollars were to be benchmarked by reference to LIBOR, not the domestic lending rate, while TNMM for AE sales was upheld and excluded comparables were sustained. A separate adjustment on outstanding receivables was rejected where working-capital effects were already reflected. The section 14A amount was also not added to book profit under MAT.
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