Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Surrendered excess stock and cash identified during a survey were characterised as business income where the taxpayer consistently offered them as miscellaneous business income, dealt regularly in the excess stock, and had no independent undisclosed asset or non-business income source. Such income was therefore taxable at normal rates. The enhanced rate introduced under section 115BBE applied prospectively from Financial Year 2017-18, corresponding to AY 2018-19, and did not apply to AY 2017-18. Disallowance of investment-related expenditure under section 14A was sustained as statutorily computed, and ad hoc disallowances of specified business expenses were also sustained where ledger extracts and cash payments did not justify interference.
Surrendered excess stock and cash identified during a survey were characterised as business income where the taxpayer consistently offered them as miscellaneous business income, dealt regularly in the excess stock, and had no independent undisclosed asset or non-business income source. Such income was therefore taxable at normal rates. The enhanced rate introduced under section 115BBE applied prospectively from Financial Year 2017-18, corresponding to AY 2018-19, and did not apply to AY 2017-18. Disallowance of investment-related expenditure under section 14A was sustained as statutorily computed, and ad hoc disallowances of specified business expenses were also sustained where ledger extracts and cash payments did not justify interference.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
