Business expenditure and depreciation rules allow operational outgoings while limiting disallowances for personal elements and unsupported third-party...
Compromise-and-arrangement extensions may accommodate debt assignment where creditor commercial judgment supports value maximisation and avoids proced...
Delayed-payment surcharge is not taxable tolerance consideration where it penalises default, while meter testing follows electricity distribution trea...
Sufficient cause for delayed revenue income-tax appeals requires bona fides, due diligence and a credible explanation; otherwise limitation bars appea...
Inverted-duty-structure refunds remain available for unchanged-rate apparel supplies despite trader status and require tax-period-specific computation...
Prescribed transfer-pricing methods must govern arm's length price determination; an ad hoc allocation of consideration between independently negotiated business-transfer and intellectual-property agreements cannot be sustained without comparable analysis, valuation, benchmarking or another recognised methodology. Advertisement, marketing and promotion expenditure alone does not establish economic ownership of marketing intangibles or permit rewriting arm's length agreements absent sham or collusion. The transfer-pricing adjustment was deleted without remand. The dividend distribution tax treaty-rate claim was remitted for action dependent on pending Supreme Court proceedings. Interest for delayed return filing caused by an undisputed e-filing portal glitch was deleted, while the assessment-limitation challenge became infructuous following retrospective amendments.
Prescribed transfer-pricing methods must govern arm's length price determination; an ad hoc allocation of consideration between independently negotiated business-transfer and intellectual-property agreements cannot be sustained without comparable analysis, valuation, benchmarking or another recognised methodology. Advertisement, marketing and promotion expenditure alone does not establish economic ownership of marketing intangibles or permit rewriting arm's length agreements absent sham or collusion. The transfer-pricing adjustment was deleted without remand. The dividend distribution tax treaty-rate claim was remitted for action dependent on pending Supreme Court proceedings. Interest for delayed return filing caused by an undisputed e-filing portal glitch was deleted, while the assessment-limitation challenge became infructuous following retrospective amendments.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
