Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
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 comparability must meet statutory requirements; taxpayer-selected comparables cannot be replaced merely with a standard departmental set. Functional dissimilarity, abnormal margins, turnover, contractual risk profile and related-party transactions may justify exclusion, with a lower related-party threshold preferred where adequate uncontrolled comparables exist. Foreign-exchange gains or losses are operating items only when directly linked to the relevant international transaction. Reliable subsequently available data may support appellate-stage comparable changes, subject to statutory conditions. The prescribed variation is a tolerance range, not a standard deduction. Working-capital adjustment addresses material margin differences rather than selecting comparables. Comparable-selection burdens rest on the party making the relevant assertion, and cross-objections are unavailable in appeals under section 260A.
Transfer-pricing comparability must meet statutory requirements; taxpayer-selected comparables cannot be replaced merely with a standard departmental set. Functional dissimilarity, abnormal margins, turnover, contractual risk profile and related-party transactions may justify exclusion, with a lower related-party threshold preferred where adequate uncontrolled comparables exist. Foreign-exchange gains or losses are operating items only when directly linked to the relevant international transaction. Reliable subsequently available data may support appellate-stage comparable changes, subject to statutory conditions. The prescribed variation is a tolerance range, not a standard deduction. Working-capital adjustment addresses material margin differences rather than selecting comparables. Comparable-selection burdens rest on the party making the relevant assertion, and cross-objections are unavailable in appeals under section 260A.
Note: It is a system-generated summary and is for quick reference only.
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