Tax deduction compliance and payee income recognition govern consultancy disallowance, while no exempt income prevents related expenditure disallowanc...
Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Omission of the specified domestic transaction provision for related-party expenditure, without a saving clause for pending actions, treats the omitted provision as if it had never existed. Consequently, transfer-pricing cognizance taken under that omitted provision, the reference to the Transfer Pricing Officer, and consequential transfer-pricing proceedings lack validity. Applying this settled position, the Tribunal allowed the taxpayer's grounds and did not sustain the assessment founded on the impugned transfer-pricing reference.
Omission of the specified domestic transaction provision for related-party expenditure, without a saving clause for pending actions, treats the omitted provision as if it had never existed. Consequently, transfer-pricing cognizance taken under that omitted provision, the reference to the Transfer Pricing Officer, and consequential transfer-pricing proceedings lack validity. Applying this settled position, the Tribunal allowed the taxpayer's grounds and did not sustain the assessment founded on the impugned transfer-pricing reference.
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