Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
Imported educational software supplied on CDs to educational institutions was treated as packaged, rather than customized, software where identical unmodifiable products were marketed to varied users and related consultation, installation, training and support did not alter the software. MRP/RSP-based valuation applied because packages lacked the mandatory "not for retail sale" declaration required for the industrial or institutional consumer exclusion. Customer and sub-reseller invoices supported the retail sale price; installation, training and support costs were not deductible without a separate invoice break-up. Non-declaration of MRP supported extended limitation, confiscation and penalties, sustained alongside differential CVD.
Imported educational software supplied on CDs to educational institutions was treated as packaged, rather than customized, software where identical unmodifiable products were marketed to varied users and related consultation, installation, training and support did not alter the software. MRP/RSP-based valuation applied because packages lacked the mandatory "not for retail sale" declaration required for the industrial or institutional consumer exclusion. Customer and sub-reseller invoices supported the retail sale price; installation, training and support costs were not deductible without a separate invoice break-up. Non-declaration of MRP supported extended limitation, confiscation and penalties, sustained alongside differential CVD.
Note: It is a system-generated summary and is for quick reference only.