Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
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.
Note: It is a system-generated summary and is for quick reference only.
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