Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
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Assessment-order limitation depends on when the order is made or passed within the statutory period, not on later dispatch, communication or receipt; a dated order remains timely absent material showing it was actually made later. Rental income reflected in Form 26AS cannot be added without verifying whether timing differences from straight-line lease-rental recognition have already been taxed in another year. Interest on refinancing may qualify for deduction under section 24(b) only where a direct nexus connects the original borrowing, property acquisition or construction, and subsequent loan. Tenant-wise reconciliation and refinancing fund-flow evidence require fresh verification; the limitation challenge was rejected, while the rental and interest issues were remanded.
Assessment-order limitation depends on when the order is made or passed within the statutory period, not on later dispatch, communication or receipt; a dated order remains timely absent material showing it was actually made later. Rental income reflected in Form 26AS cannot be added without verifying whether timing differences from straight-line lease-rental recognition have already been taxed in another year. Interest on refinancing may qualify for deduction under section 24(b) only where a direct nexus connects the original borrowing, property acquisition or construction, and subsequent loan. Tenant-wise reconciliation and refinancing fund-flow evidence require fresh verification; the limitation challenge was rejected, while the rental and interest issues were remanded.
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