Timing mismatch in income recognition requires verification whether receipts were already taxed in an earlier year; matter remitted for fresh examinat...
FOB transaction value and export incentives: customs valuation cannot override contractual export benefits or support confiscation without valid proof...
Corporate guarantee commission under the interest saving method required allocation of the benefit between guarantor and borrower; in the absence of fuller facts, the Tribunal directed a 50:50 split and clarified that this is fact-specific, not a universal rule. Book profit computation could not be increased by the Section 14A disallowance in the manner adopted by the Assessing Officer; following Vireet Investment, the figure had to be recomputed under clause (f) of Explanation 1 without applying Rule 8D. For the set-aside years, the Assessing Officer was also directed to verify the assessment records, consider the assessee's submissions, and recompute total income after giving effect to earlier reliefs.
Corporate guarantee commission under the interest saving method required allocation of the benefit between guarantor and borrower; in the absence of fuller facts, the Tribunal directed a 50:50 split and clarified that this is fact-specific, not a universal rule. Book profit computation could not be increased by the Section 14A disallowance in the manner adopted by the Assessing Officer; following Vireet Investment, the figure had to be recomputed under clause (f) of Explanation 1 without applying Rule 8D. For the set-aside years, the Assessing Officer was also directed to verify the assessment records, consider the assessee's submissions, and recompute total income after giving effect to earlier reliefs.
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