Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
For pre-amendment years, completed but unsold flats held by a builder as stock-in-trade are not subject to notional annual letting value under the general house-property provisions. The specific rule for stock-in-trade property applies prospectively from Assessment Year 2018-19, so its treatment cannot be extended to earlier years. Transfer-pricing adjustments to marketing brokerage require a recognised benchmarking method, reliable comparable or market evidence, and functional analysis of the services performed. Replacing an agreed brokerage rate with a general estimated market rate, without examining marketing, sales-support and customer-related functions, lacks an adequate arm's-length basis.
For pre-amendment years, completed but unsold flats held by a builder as stock-in-trade are not subject to notional annual letting value under the general house-property provisions. The specific rule for stock-in-trade property applies prospectively from Assessment Year 2018-19, so its treatment cannot be extended to earlier years. Transfer-pricing adjustments to marketing brokerage require a recognised benchmarking method, reliable comparable or market evidence, and functional analysis of the services performed. Replacing an agreed brokerage rate with a general estimated market rate, without examining marketing, sales-support and customer-related functions, lacks an adequate arm's-length basis.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
