Effective hearing in GST adjudication requires actual opportunity to respond; ineffective service through a former auditor invalidated ex parte procee...
Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedin...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain ex...
Insolvency moratorium bars income-tax revision proceedings against corporate debtors until the moratorium ends, preserving merits for later determinat...
TNMM aggregation prevented separate benchmarking of IT support services where accepted segmental margins already included the associated-enterprise markup and the services were inextricably linked to the core business. The transfer-pricing adjustment on the IT support-services margin was deleted. Notional interest on overdue associated-enterprise receivables was unwarranted because the taxpayer was debt-free, incurred no significant interest cost, and no new material justified departure from earlier treatment; the related adjustment was deleted. Capital expenditure on an in-house scientific-research facility remained deductible under section 35(1)(iv) despite the concessional tax regime and absence of valid Form 3CM, which was relevant to section 35(2AB), not section 35(1)(iv).
TNMM aggregation prevented separate benchmarking of IT support services where accepted segmental margins already included the associated-enterprise markup and the services were inextricably linked to the core business. The transfer-pricing adjustment on the IT support-services margin was deleted. Notional interest on overdue associated-enterprise receivables was unwarranted because the taxpayer was debt-free, incurred no significant interest cost, and no new material justified departure from earlier treatment; the related adjustment was deleted. Capital expenditure on an in-house scientific-research facility remained deductible under section 35(1)(iv) despite the concessional tax regime and absence of valid Form 3CM, which was relevant to section 35(2AB), not section 35(1)(iv).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
