Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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