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...
Consequential transfer pricing orders were held time-barred because the limitation period depended on the nature of the earlier appellate directions. Where the prior Tribunal order sent the issues on advances to associated enterprises and interest on outstanding receivables back for verification, hearing, and application of directions, the matter was treated as a fresh assessment on remand under section 153(3), with the second proviso to section 153(5) leading to the same result. Where the arm's length commission on corporate guarantees had already been conclusively fixed at 0.5% and only implementation remained, section 153(5) applied. In both situations, the consequential orders passed on 06.12.2024 were beyond time and were set aside.
Consequential transfer pricing orders were held time-barred because the limitation period depended on the nature of the earlier appellate directions. Where the prior Tribunal order sent the issues on advances to associated enterprises and interest on outstanding receivables back for verification, hearing, and application of directions, the matter was treated as a fresh assessment on remand under section 153(3), with the second proviso to section 153(5) leading to the same result. Where the arm's length commission on corporate guarantees had already been conclusively fixed at 0.5% and only implementation remained, section 153(5) applied. In both situations, the consequential orders passed on 06.12.2024 were beyond time and were set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
