Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Cost-to-cost reimbursements of third-party marketing, promotion, travel and other expenses involving no services or value addition do not warrant an upward transfer-pricing adjustment; domestic-group recoveries require verification. Salary and wage cross-charges from foreign associated enterprises remain subject to adjustment where shared employee services are insufficiently substantiated. Television-channel distribution licence fees should be benchmarked under the Comparable Uncontrolled Price method where comparable licence agreements exist; software and IT distributors are not functionally comparable. A foreign-tax deduction claim not made in the return may be raised before appellate authorities, but requires factual verification where tax credit was unavailable or unclaimed.
Cost-to-cost reimbursements of third-party marketing, promotion, travel and other expenses involving no services or value addition do not warrant an upward transfer-pricing adjustment; domestic-group recoveries require verification. Salary and wage cross-charges from foreign associated enterprises remain subject to adjustment where shared employee services are insufficiently substantiated. Television-channel distribution licence fees should be benchmarked under the Comparable Uncontrolled Price method where comparable licence agreements exist; software and IT distributors are not functionally comparable. A foreign-tax deduction claim not made in the return may be raised before appellate authorities, but requires factual verification where tax credit was unavailable or unclaimed.
Note: It is a system-generated summary and is for quick reference only.
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