Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Foreign withholding tax eligible for double-taxation relief under sections 90 or 91 cannot be deducted as business expenditure merely because nil Indian tax liability prevents use of the credit. Explanation 1 to section 40(a)(ii) applies based on eligibility for relief, not actual allowance or utilisation; the claimed deduction was therefore rejected. An additional legal claim for that deduction, raised before the first appellate authority, required examination on merits where the return and Form 67 contained the relevant material. Rule 46A did not justify threshold rejection, although the claim ultimately failed.
Foreign withholding tax eligible for double-taxation relief under sections 90 or 91 cannot be deducted as business expenditure merely because nil Indian tax liability prevents use of the credit. Explanation 1 to section 40(a)(ii) applies based on eligibility for relief, not actual allowance or utilisation; the claimed deduction was therefore rejected. An additional legal claim for that deduction, raised before the first appellate authority, required examination on merits where the return and Form 67 contained the relevant material. Rule 46A did not justify threshold rejection, although the claim ultimately failed.
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