Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Corporate guarantees issued for an associated enterprise's borrowing fall within capital financing and constitute international transactions where they enhance the enterprise's creditworthiness and expose the guarantor to risk. Arm's-length pricing is therefore required. Where no pricing method or transfer-pricing study computation is provided, an annual 0.5% guarantee fee determined using the uncontrolled-price standard under Rule 10AB is sustained. Guarantee fee is not profit derived from SEZ development and is ineligible for the SEZ deduction. Tax deducted at source credit reflected in Form 26AS requires verification before eligible credit is granted.
Corporate guarantees issued for an associated enterprise's borrowing fall within capital financing and constitute international transactions where they enhance the enterprise's creditworthiness and expose the guarantor to risk. Arm's-length pricing is therefore required. Where no pricing method or transfer-pricing study computation is provided, an annual 0.5% guarantee fee determined using the uncontrolled-price standard under Rule 10AB is sustained. Guarantee fee is not profit derived from SEZ development and is ineligible for the SEZ deduction. Tax deducted at source credit reflected in Form 26AS requires verification before eligible credit is granted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4878 
