Rental income valuation requires credible local comparables; family-business salary and commercially expedient unsecured-loan interest remained deduct...
Strict construction of customs exemptions denied concession for brake components, while limitation restricted differential duty to timely Bills of Ent...
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Partial appellate remand of transfer-pricing comparability issues, without setting aside or cancelling the assessment, requires effect to be given otherwise than through a fresh assessment. Where the remand requires fresh examination and hearing, the limitation period applicable to consequential action applies. A Tribunal remand to the Transfer Pricing Officer does not constitute an Assessing Officer's reference to that officer and therefore does not trigger the additional limitation extension available for such a reference. The consequential assessment, completed after the prescribed deadline, was quashed as time-barred; the remaining transfer-pricing challenges became infructuous.
Partial appellate remand of transfer-pricing comparability issues, without setting aside or cancelling the assessment, requires effect to be given otherwise than through a fresh assessment. Where the remand requires fresh examination and hearing, the limitation period applicable to consequential action applies. A Tribunal remand to the Transfer Pricing Officer does not constitute an Assessing Officer's reference to that officer and therefore does not trigger the additional limitation extension available for such a reference. The consequential assessment, completed after the prescribed deadline, was quashed as time-barred; the remaining transfer-pricing challenges became infructuous.
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