Commodity derivatives position limits adopt revised breach penalties, broad commodity criteria, and client open-position limits based on deliverable s...
Effective hearing in GST adjudication requires actual opportunity to respond; ineffective service through a former auditor invalidated ex parte procee...
Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedin...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain ex...
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.
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TaxTMI 
TaxTMI 
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