Retrospective cancellation of charitable registration under section 12AB(4) was unsustainable; related-party benefit allegations did not prove nongenu...
Merger control notice and disclosure rules: Supreme Court limits penalties, rejects reopening of approved combination, and sets aside adverse findings...
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Reassessment beyond four years following an assessment under section 143(3) requires failure by the taxpayer to make a full and true disclosure of material facts. The notes state that where the subsidy was disclosed in the financial statements and considered originally, reopening without fresh material constitutes a change of opinion and is invalid. For transfer-pricing benchmarking, an associated enterprise subsidy that routinely compensates unabsorbed distribution costs and is directly linked to distribution operations is treated as operating income. Such subsidy must be included when benchmarking closely linked distribution transactions, rather than excluded in making a transfer-pricing adjustment.
Reassessment beyond four years following an assessment under section 143(3) requires failure by the taxpayer to make a full and true disclosure of material facts. The notes state that where the subsidy was disclosed in the financial statements and considered originally, reopening without fresh material constitutes a change of opinion and is invalid. For transfer-pricing benchmarking, an associated enterprise subsidy that routinely compensates unabsorbed distribution costs and is directly linked to distribution operations is treated as operating income. Such subsidy must be included when benchmarking closely linked distribution transactions, rather than excluded in making a transfer-pricing adjustment.
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