Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Expenditure is disallowable under Explanation 1 to section 37(1) only where it is shown to relate to an offence or an act prohibited by law; because no punitive action had been taken by the competent insurance regulator, the disallowance was deleted. For insurance business income, section 44 with the First Schedule provides a special computation regime that overrides the general computation rules, so section 14A read with Rule 8D does not apply to an insurer. The prior co-ordinate bench view in the assessee's own case was followed.
Expenditure is disallowable under Explanation 1 to section 37(1) only where it is shown to relate to an offence or an act prohibited by law; because no punitive action had been taken by the competent insurance regulator, the disallowance was deleted. For insurance business income, section 44 with the First Schedule provides a special computation regime that overrides the general computation rules, so section 14A read with Rule 8D does not apply to an insurer. The prior co-ordinate bench view in the assessee's own case was followed.
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