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...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Delayed recovery of associated enterprise receivables was held not to justify a working capital transfer pricing adjustment where the branch was debt-free, had no borrowings or interest claim, and its working capital needs were funded by head office, so no opportunity cost or borrowed-funds assumption was shown. The Tribunal therefore found no basis to interfere with deletion of the adjustment. Interest under section 234D was treated as consequential, and that ground was accepted on the assessee's concession.
Delayed recovery of associated enterprise receivables was held not to justify a working capital transfer pricing adjustment where the branch was debt-free, had no borrowings or interest claim, and its working capital needs were funded by head office, so no opportunity cost or borrowed-funds assumption was shown. The Tribunal therefore found no basis to interfere with deletion of the adjustment. Interest under section 234D was treated as consequential, and that ground was accepted on the assessee's concession.
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