Questions arising from miscellaneous application orders cannot challenge unaltered Tribunal findings, leaving the original order separately challengea...
Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
DCF valuation adopted for share premium under Rule 11UA cannot be replaced by the NAV method merely because projected results differ from subsequent actual performance. Consistent acceptance of the same premium in earlier years and for identical shares issued to non-residents supports equivalent treatment for resident shareholders. Occupancy certificates do not determine the deductibility of borrowing interest where commercial buildings have been put to use, rental income is assessed as business income, and borrowings funded construction. Advertisement and marketing costs for commercial space remain allowable business expenditure where incurred for commercial exploitation, notwithstanding a subsequently obtained occupancy certificate.
DCF valuation adopted for share premium under Rule 11UA cannot be replaced by the NAV method merely because projected results differ from subsequent actual performance. Consistent acceptance of the same premium in earlier years and for identical shares issued to non-residents supports equivalent treatment for resident shareholders. Occupancy certificates do not determine the deductibility of borrowing interest where commercial buildings have been put to use, rental income is assessed as business income, and borrowings funded construction. Advertisement and marketing costs for commercial space remain allowable business expenditure where incurred for commercial exploitation, notwithstanding a subsequently obtained occupancy certificate.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
