Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Section 263 revision requires both inadequate enquiry and an unsustainable Assessing Officer view; where questionnaires, replies, office notes and correspondence show that issues were examined, revision cannot rest on mere disagreement. The notes further state that revision initiated through monitoring, pressure or dictates of higher departmental authorities is invalid where the assessments followed adequate enquiry, while other grounds may remain open. An interest-free advance to a wholly owned overseas subsidiary may constitute quasi-equity or shareholder funding, rather than a loan intended to earn interest, where it supports expansion and returns are expected through the assessee's business; a LIBOR-based adjustment is therefore unsustainable. Purchases supported by commercial records and made for business purposes may qualify as commercially expedient expenditure despite expiry of a distributorship agreement.
Section 263 revision requires both inadequate enquiry and an unsustainable Assessing Officer view; where questionnaires, replies, office notes and correspondence show that issues were examined, revision cannot rest on mere disagreement. The notes further state that revision initiated through monitoring, pressure or dictates of higher departmental authorities is invalid where the assessments followed adequate enquiry, while other grounds may remain open. An interest-free advance to a wholly owned overseas subsidiary may constitute quasi-equity or shareholder funding, rather than a loan intended to earn interest, where it supports expansion and returns are expected through the assessee's business; a LIBOR-based adjustment is therefore unsustainable. Purchases supported by commercial records and made for business purposes may qualify as commercially expedient expenditure despite expiry of a distributorship agreement.
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