Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Capital-goods exemption covers plant-modernisation accessories, while the import restriction applies only to earlier capital-goods components and spar...
Constitutional judicial review permits challenges to ECIRs and connected money-laundering proceedings where coercive action affects fundamental intere...
Foreign-currency loans repayable in US dollars were benchmarked using LIBOR plus 300 basis points rather than a domestic lending rate, and that transfer-pricing direction was sustained. Under TNMM, comparables must satisfy functional and product comparability; sectorally distinct engineering services and aluminium-capacitor manufacturing entities were excluded. No arm's-length interest adjustment applied to delayed associated-enterprise receivables where no interest was charged to either associated or non-associated enterprises and transaction pricing already reflected margins. Expenditure relating to investments could not be disallowed where no exempt dividend income was received or receivable during the year. The assessee's and Revenue's appeals were dismissed.
Foreign-currency loans repayable in US dollars were benchmarked using LIBOR plus 300 basis points rather than a domestic lending rate, and that transfer-pricing direction was sustained. Under TNMM, comparables must satisfy functional and product comparability; sectorally distinct engineering services and aluminium-capacitor manufacturing entities were excluded. No arm's-length interest adjustment applied to delayed associated-enterprise receivables where no interest was charged to either associated or non-associated enterprises and transaction pricing already reflected margins. Expenditure relating to investments could not be disallowed where no exempt dividend income was received or receivable during the year. The assessee's and Revenue's appeals were dismissed.
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