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...
Internal TNMM supports deletion of freight-forwarding adjustments where comparable non-AE transactions are separately identifiable and materially simi...
Compulsorily convertible debentures that require interest payments, confer no pre-conversion voting rights and preserve a debtor-creditor relationship cannot be treated as equity solely because conversion is mandatory. Accordingly, nil arm's-length pricing of interest and the related disallowance were unsustainable without applying the prescribed transfer-pricing framework. Additional evidence on actual services, cost allocation and benchmarking required fresh determination of the business-support-services adjustment. An employment-related deduction claim supported by a revised computation and Form No. 10DA also required factual and statutory examination. A challenge to penalty initiation was premature because no penalty had crystallised.
Compulsorily convertible debentures that require interest payments, confer no pre-conversion voting rights and preserve a debtor-creditor relationship cannot be treated as equity solely because conversion is mandatory. Accordingly, nil arm's-length pricing of interest and the related disallowance were unsustainable without applying the prescribed transfer-pricing framework. Additional evidence on actual services, cost allocation and benchmarking required fresh determination of the business-support-services adjustment. An employment-related deduction claim supported by a revised computation and Form No. 10DA also required factual and statutory examination. A challenge to penalty initiation was premature because no penalty had crystallised.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
