Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
Annual election between the Income-tax Act and the applicable tax treaty permits an assessee to select the more beneficial regime independently for each assessment year, with no identified bar on changing that option across years. Where treaty treatment under the India-Mauritius DTAA renders capital gains non-taxable in India, earlier short-term capital losses validly carried forward need not be set off against those exempt gains. Those losses may therefore continue to be carried forward. The Revenue's challenge to further carry forward of the losses failed on merits, while the reassessment challenge became infructuous.
Annual election between the Income-tax Act and the applicable tax treaty permits an assessee to select the more beneficial regime independently for each assessment year, with no identified bar on changing that option across years. Where treaty treatment under the India-Mauritius DTAA renders capital gains non-taxable in India, earlier short-term capital losses validly carried forward need not be set off against those exempt gains. Those losses may therefore continue to be carried forward. The Revenue's challenge to further carry forward of the losses failed on merits, while the reassessment challenge became infructuous.
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