Independent manufacturing undertaking eligibility preserves Section 80IA/80IB deductions, while machinery kept ready for use qualifies for depreciatio...
Assessing Officer Satisfaction Requirement Bars Penalty for Cash Receipt in Immovable-Property Sale Cases Where Initiation Lacks Recorded Satisfaction...
Self-assessed import entries remain appealable, while bona fide classification disputes without misdeclaration cannot justify confiscation or penaltie...
Actual-user customs exemption conditions permit turnkey project transfers when imported windmill components are exclusively used for installation and ...
Customs offence disqualification excludes civil contraventions, preventing refusal of a private bonded warehouse licence based solely on monetary pena...
TNMM benchmarking required exclusion of functionally dissimilar, diversified, and unsegmented companies from the comparable set for manufacturing and engineering-estimation segments. Intra-group support-service charges required fresh verification of evidence showing benefits received and benchmarking under TNMM; the issue was remanded. Business-connected reversals, miscellaneous income, foreign-exchange gains and export incentives were treated as operating income where related expenditure had been treated as operating, increasing the profit level indicator. In the extraordinary COVID-affected year, current-year margins of final comparables were required for comparison rather than weighted averages including normal years. Interest on overdue associated-enterprise receivables was not imputable where audited accounts showed the taxpayer was debt-free and lease liabilities were not borrowings.
TNMM benchmarking required exclusion of functionally dissimilar, diversified, and unsegmented companies from the comparable set for manufacturing and engineering-estimation segments. Intra-group support-service charges required fresh verification of evidence showing benefits received and benchmarking under TNMM; the issue was remanded. Business-connected reversals, miscellaneous income, foreign-exchange gains and export incentives were treated as operating income where related expenditure had been treated as operating, increasing the profit level indicator. In the extraordinary COVID-affected year, current-year margins of final comparables were required for comparison rather than weighted averages including normal years. Interest on overdue associated-enterprise receivables was not imputable where audited accounts showed the taxpayer was debt-free and lease liabilities were not borrowings.
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