Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Internal CUP was treated as the most appropriate method for determining the arm's length price of project-office transactions under a turnkey power-project contract. Where the Indian project office bore the contract's risks and rewards, all revenue was attributed to India, and the unrelated customer regarded the head office and project office as one entity, the contract with that customer satisfied the comparability requirements for an internal CUP. CUP was preferred over TNMM as a more direct and suitable method, while the proposed TNMM comparables were rejected. The transfer-pricing adjustment was consequently not sustained, and the appeals were dismissed for lack of a substantial question of law.
Internal CUP was treated as the most appropriate method for determining the arm's length price of project-office transactions under a turnkey power-project contract. Where the Indian project office bore the contract's risks and rewards, all revenue was attributed to India, and the unrelated customer regarded the head office and project office as one entity, the contract with that customer satisfied the comparability requirements for an internal CUP. CUP was preferred over TNMM as a more direct and suitable method, while the proposed TNMM comparables were rejected. The transfer-pricing adjustment was consequently not sustained, and the appeals were dismissed for lack of a substantial question of law.
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