Fake-invoice penalties remain available where taxpayer admissions and records establish unsupported input tax credit claims and false GST documentatio...
Works contract classification applies to permanently installed fire-protection systems, while earthwork and obsolete IGST concessions remain unavailab...
Professional fee recovery for GST refund representation succeeds where direct engagement, fee acknowledgement, and authority are established despite c...
Transfer pricing of intra-group support services requires prescribed benchmarking; unsupported nil valuation and alternate business-expense disallowan...
Compulsory conversion of debentures and the absence of cash redemption may affect comparable selection or adjustments, but do not by themselves justify treating an express pre-conversion coupon as having a nil arm's-length price. Recharacterisation requires facts showing that economic substance differs from legal form, or that reliable pricing is unavailable; no uncontrolled transaction supported a nil return under the Other Method. The nil-ALP adjustment was deleted, without establishing any universal arm's-length coupon rate. The related interest disallowance was also set aside for lack of an independent finding on business nexus or use of funds. Interest-limitation and statutory-interest computations require consequential verification, recomputation, and identification of the charging provision.
Compulsory conversion of debentures and the absence of cash redemption may affect comparable selection or adjustments, but do not by themselves justify treating an express pre-conversion coupon as having a nil arm's-length price. Recharacterisation requires facts showing that economic substance differs from legal form, or that reliable pricing is unavailable; no uncontrolled transaction supported a nil return under the Other Method. The nil-ALP adjustment was deleted, without establishing any universal arm's-length coupon rate. The related interest disallowance was also set aside for lack of an independent finding on business nexus or use of funds. Interest-limitation and statutory-interest computations require consequential verification, recomputation, and identification of the charging provision.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
