Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Residual Profit Split Method, once accepted and computed for an integrated IT-enabled and data analytics services transaction, cannot be supplemented by a further entity-level margin comparison using another transfer-pricing method. A different prescribed method may be used only after RPSM is rejected for cogent reasons; the entity-level adjustment was therefore deleted. Corporate guarantee pricing cannot mechanically adopt commercial bank-guarantee rates. The interest-saving approach requires transaction-specific analysis of the associated enterprise's credit profile, borrowing terms, currency, tenure, security and guarantee coverage; the guarantee commission was remanded for fresh determination. Current-year business-loss set-off requires verification against return, computation and assessment records.
Residual Profit Split Method, once accepted and computed for an integrated IT-enabled and data analytics services transaction, cannot be supplemented by a further entity-level margin comparison using another transfer-pricing method. A different prescribed method may be used only after RPSM is rejected for cogent reasons; the entity-level adjustment was therefore deleted. Corporate guarantee pricing cannot mechanically adopt commercial bank-guarantee rates. The interest-saving approach requires transaction-specific analysis of the associated enterprise's credit profile, borrowing terms, currency, tenure, security and guarantee coverage; the guarantee commission was remanded for fresh determination. Current-year business-loss set-off requires verification against return, computation and assessment records.
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