Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
Section 80P deduction for co-operative societies remains available despite nominal members and housing society status, with limited interest income tr...
Employee benefit expenses were not to be disallowed merely because managerial remuneration increased while revenue declined, where the expenditure was genuine, business-related and supported by material showing services rendered. The reasonableness of remuneration had to be judged from the businessman's perspective, not on the Assessing Officer's subjective view, and the Rule 46A objection failed because the relied-on documents were not treated as additional evidence requiring remand. On transfer pricing, interest on rupee-denominated non-convertible debentures was benchmarked against the Prime Lending Rate, not EBLR; on that basis the coupon rate was treated as arm's length and the adjustment was deleted.
Employee benefit expenses were not to be disallowed merely because managerial remuneration increased while revenue declined, where the expenditure was genuine, business-related and supported by material showing services rendered. The reasonableness of remuneration had to be judged from the businessman's perspective, not on the Assessing Officer's subjective view, and the Rule 46A objection failed because the relied-on documents were not treated as additional evidence requiring remand. On transfer pricing, interest on rupee-denominated non-convertible debentures was benchmarked against the Prime Lending Rate, not EBLR; on that basis the coupon rate was treated as arm's length and the adjustment was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
