Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
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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