Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
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 4881 
