Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Demand and penalty-initiation notices cannot rest on an order expressly issued as a draft assessment order. Where proposed disallowances remain proposals, no demand or penalty notice is issued, and the taxpayer retains the right to accept variations or object before final assessment, the payable sum has not been finally determined. Such a defect is not a mere uploading error curable through Section 292B, especially without a subsequent corrective or clarificatory order. Draft assessment procedure is also unavailable where the Transfer Pricing Officer makes no variation to returned income from international transactions; the taxpayer is then not an eligible assessee under Section 144C. The draft order and consequential notices were set aside.
Demand and penalty-initiation notices cannot rest on an order expressly issued as a draft assessment order. Where proposed disallowances remain proposals, no demand or penalty notice is issued, and the taxpayer retains the right to accept variations or object before final assessment, the payable sum has not been finally determined. Such a defect is not a mere uploading error curable through Section 292B, especially without a subsequent corrective or clarificatory order. Draft assessment procedure is also unavailable where the Transfer Pricing Officer makes no variation to returned income from international transactions; the taxpayer is then not an eligible assessee under Section 144C. The draft order and consequential notices were set aside.
Note: It is a system-generated summary and is for quick reference only.