Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Search-related assessments initiated on or after 1 April 2021 must proceed under the reassessment framework, rather than regular scrutiny assessment provisions. Where seized material belongs to a third party, the Assessing Officer must record satisfaction that it pertains to the assessee and obtain prescribed approval; non-compliance can invalidate the assessment. For unsecured loans, identity, creditworthiness and genuineness may be established through corporate, financial, banking, confirmation and repayment records, while untested third-party statements cannot alone support additions. Transfer-pricing analysis should respect accepted guarantee-pricing methods and avoid separate interest adjustments where delayed receivables are already reflected in arm's length pricing. Cross-examination, corroboration, and a direct link to the relevant year remain necessary for unexplained-money additions.
Search-related assessments initiated on or after 1 April 2021 must proceed under the reassessment framework, rather than regular scrutiny assessment provisions. Where seized material belongs to a third party, the Assessing Officer must record satisfaction that it pertains to the assessee and obtain prescribed approval; non-compliance can invalidate the assessment. For unsecured loans, identity, creditworthiness and genuineness may be established through corporate, financial, banking, confirmation and repayment records, while untested third-party statements cannot alone support additions. Transfer-pricing analysis should respect accepted guarantee-pricing methods and avoid separate interest adjustments where delayed receivables are already reflected in arm's length pricing. Cross-examination, corroboration, and a direct link to the relevant year remain necessary for unexplained-money additions.
Note: It is a system-generated summary and is for quick reference only.
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