Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
Buy-back of a company's own shares followed by mandatory extinguishment does not entail receipt of "property" for section 56(2)(x), because the shares cannot be held, enjoyed or transferred by the company as an asset. Interest-free advances do not justify interest disallowance under section 36(1)(iii) where interest-free own funds exceed those advances and no specific borrowing is traceable to them; proportionate disallowance from a mixed pool of funds is unwarranted. Principal loans and inter-corporate deposits written off in an organised money-lending business qualify as bad debts where actual write-off occurs. A lending licence, tax-audit description and the proportion of interest income are not determinative of that business character.
Buy-back of a company's own shares followed by mandatory extinguishment does not entail receipt of "property" for section 56(2)(x), because the shares cannot be held, enjoyed or transferred by the company as an asset. Interest-free advances do not justify interest disallowance under section 36(1)(iii) where interest-free own funds exceed those advances and no specific borrowing is traceable to them; proportionate disallowance from a mixed pool of funds is unwarranted. Principal loans and inter-corporate deposits written off in an organised money-lending business qualify as bad debts where actual write-off occurs. A lending licence, tax-audit description and the proportion of interest income are not determinative of that business character.
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