Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
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 
of 4888 
