Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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 4805
Join Channel
TaxTMI 
