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...
Transfer pricing on loans to associated enterprises was confined to the LIBOR-based rate already accepted in earlier precedent, so no further interest adjustment was warranted. Corporate guarantee commission was retained at 0.35% on consistency with earlier years and the interest-saved approach. Deduction for rail and water systems as infrastructure facility under section 80-IA was allowed because the earlier orders had attained finality. The section 14A disallowance was restricted: interest disallowance was deleted where interest-free funds exceeded investments, and administrative expenditure was computed only on investments yielding exempt income, with corresponding book-profit relief. The gain on prepayment of sales tax deferral was treated as capital receipt, and the write-back of project creditors was not taxable under section 28(iv).
Transfer pricing on loans to associated enterprises was confined to the LIBOR-based rate already accepted in earlier precedent, so no further interest adjustment was warranted. Corporate guarantee commission was retained at 0.35% on consistency with earlier years and the interest-saved approach. Deduction for rail and water systems as infrastructure facility under section 80-IA was allowed because the earlier orders had attained finality. The section 14A disallowance was restricted: interest disallowance was deleted where interest-free funds exceeded investments, and administrative expenditure was computed only on investments yielding exempt income, with corresponding book-profit relief. The gain on prepayment of sales tax deferral was treated as capital receipt, and the write-back of project creditors was not taxable under section 28(iv).
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