Tax collection at source on purchases removes duplicate withholding obligation, while trade-creditor evidence requires verification before unexplained...
Transfer-pricing comparability requires material turnover effects; adjustments must cover only associated-enterprise transactions and exclude abnormal...
Scrutiny assessments founded on revised returns require a statutory notice tied to the operative revised return; its absence is an incurable jurisdictional defect not cured by participation, and assessments for three years were quashed. Pre-amendment annual Form 3CL quantification could not defeat or cap weighted research-and-development deductions where substantive approval existed, but eligibility required limited verification. Rule 8D disallowance required account-based satisfaction, excluded investments yielding taxable foreign dividends, and could not automatically increase book profit under the self-contained minimum alternate tax regime. Expenditure improving access to an existing factory remained revenue expenditure where no capital asset or proprietary advantage was acquired.
Scrutiny assessments founded on revised returns require a statutory notice tied to the operative revised return; its absence is an incurable jurisdictional defect not cured by participation, and assessments for three years were quashed. Pre-amendment annual Form 3CL quantification could not defeat or cap weighted research-and-development deductions where substantive approval existed, but eligibility required limited verification. Rule 8D disallowance required account-based satisfaction, excluded investments yielding taxable foreign dividends, and could not automatically increase book profit under the self-contained minimum alternate tax regime. Expenditure improving access to an existing factory remained revenue expenditure where no capital asset or proprietary advantage was acquired.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
