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...
Arm's-length pricing of interest on 30-year non-convertible debentures cannot rest on an unsupported minimum-tenure filter under the comparable uncontrolled price method, particularly where tenure does not uniformly determine coupon rates; the transfer-pricing adjustment was deleted. Interest limitation for debt payable to non-resident associated enterprises must exclude interest paid to non-associated enterprises and prevent duplicate disallowance of interest already affected by transfer pricing; recomputation and consequential relief were directed. Classification of assessment adjustments under the appropriate head of income requires verification of the computation and records. A challenge to penalty initiation is premature where no final penalty order is under appeal.
Arm's-length pricing of interest on 30-year non-convertible debentures cannot rest on an unsupported minimum-tenure filter under the comparable uncontrolled price method, particularly where tenure does not uniformly determine coupon rates; the transfer-pricing adjustment was deleted. Interest limitation for debt payable to non-resident associated enterprises must exclude interest paid to non-associated enterprises and prevent duplicate disallowance of interest already affected by transfer pricing; recomputation and consequential relief were directed. Classification of assessment adjustments under the appropriate head of income requires verification of the computation and records. A challenge to penalty initiation is premature where no final penalty order is under appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
