Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
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Outstanding receivables from associated enterprises, where they arose from sales transactions already benchmarked under TNMM and a working capital adjustment had been granted, did not justify a separate notional interest adjustment absent evidence of an independent financing arrangement; the adjustment was deleted. CSR-linked donations were not automatically barred from deduction merely because they were made in discharge of CSR obligations, but the claim required verification of recipient eligibility and other statutory conditions, so the matter was remitted. Grounds challenging initiation of penalty proceedings were treated as premature because no final penalty order was under appeal. The treaty-based claim for refund of excess dividend distribution tax was also restored for fresh adjudication.
Outstanding receivables from associated enterprises, where they arose from sales transactions already benchmarked under TNMM and a working capital adjustment had been granted, did not justify a separate notional interest adjustment absent evidence of an independent financing arrangement; the adjustment was deleted. CSR-linked donations were not automatically barred from deduction merely because they were made in discharge of CSR obligations, but the claim required verification of recipient eligibility and other statutory conditions, so the matter was remitted. Grounds challenging initiation of penalty proceedings were treated as premature because no final penalty order was under appeal. The treaty-based claim for refund of excess dividend distribution tax was also restored for fresh adjudication.
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