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...
Tax deductions and transfer-pricing treatment turn on statutory conditions rather than administrative quantification or unsupported adjustments. Expenditure incurred at an approved in-house R&D facility qualified for weighted deduction despite incomplete Form 3CL quantification; delegated rules could not restrict the statutory measure of eligible expenditure. For exempt-income disallowance, objective satisfaction from the accounts is required before applying Rule 8D, and interest-free funds exceeding investments preclude interest disallowance. Pre-amendment CSR expenditure remained deductible, whereas CSR spending subject to the later statutory Explanation was not deductible as business expenditure, although eligible donations could qualify under section 80G. Offshore goods purchases without Indian tax chargeability did not require withholding. Transfer-pricing adjustments required prescribed methods and reliable comparables; nil valuation or arbitrary royalty reductions were unsustainable. Summary-intimation adjustments adopted in regular assessment merged into that assessment and could be contested on merits.
Tax deductions and transfer-pricing treatment turn on statutory conditions rather than administrative quantification or unsupported adjustments. Expenditure incurred at an approved in-house R&D facility qualified for weighted deduction despite incomplete Form 3CL quantification; delegated rules could not restrict the statutory measure of eligible expenditure. For exempt-income disallowance, objective satisfaction from the accounts is required before applying Rule 8D, and interest-free funds exceeding investments preclude interest disallowance. Pre-amendment CSR expenditure remained deductible, whereas CSR spending subject to the later statutory Explanation was not deductible as business expenditure, although eligible donations could qualify under section 80G. Offshore goods purchases without Indian tax chargeability did not require withholding. Transfer-pricing adjustments required prescribed methods and reliable comparables; nil valuation or arbitrary royalty reductions were unsustainable. Summary-intimation adjustments adopted in regular assessment merged into that assessment and could be contested on merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
