Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
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Return-processing adjustments cannot disallow diminution in the value of a business-purpose investment in a wholly owned subsidiary solely because a tax audit report describes it as capital expenditure where binding jurisdictional precedent permits an analogous business loss. Once an intimation is issued after considering the taxpayer's response, the Centralised Processing Centre performs a quasi-judicial function and must follow binding High Court law. Failure to consider a jurisdictional High Court decision delivered before the intimation, and specifically raised in a rectification application, constitutes a mistake apparent from the record. The resulting disallowance requires rectification in accordance with that precedent.
Return-processing adjustments cannot disallow diminution in the value of a business-purpose investment in a wholly owned subsidiary solely because a tax audit report describes it as capital expenditure where binding jurisdictional precedent permits an analogous business loss. Once an intimation is issued after considering the taxpayer's response, the Centralised Processing Centre performs a quasi-judicial function and must follow binding High Court law. Failure to consider a jurisdictional High Court decision delivered before the intimation, and specifically raised in a rectification application, constitutes a mistake apparent from the record. The resulting disallowance requires rectification in accordance with that precedent.
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