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...
Financial irregularities found by SEBI rendered Acropetal Technologies Ltd.'s accounts and margins unreliable, so its exclusion from the comparables set was upheld for transfer pricing purposes. The Tribunal noted that diversion of funds to non-business use can materially distort operating margins and followed prior co-ordinate bench decisions excluding the same company. For intra-group support services, it accepted that a later APA margin could have persuasive value for a non-APA year where the transactions were identical, the FAR profile was unchanged, and documentary evidence supported receipt of services. The transfer pricing adjustment on support services was therefore deleted.
Financial irregularities found by SEBI rendered Acropetal Technologies Ltd.'s accounts and margins unreliable, so its exclusion from the comparables set was upheld for transfer pricing purposes. The Tribunal noted that diversion of funds to non-business use can materially distort operating margins and followed prior co-ordinate bench decisions excluding the same company. For intra-group support services, it accepted that a later APA margin could have persuasive value for a non-APA year where the transactions were identical, the FAR profile was unchanged, and documentary evidence supported receipt of services. The transfer pricing adjustment on support services was therefore deleted.
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