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    August 6, 2026   Case Laws Income Tax
    International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability governs software service margins.
    August 6, 2026   Case Laws Income Tax
    Asset-based escaped-income satisfaction is mandatory for extended Section 153C jurisdiction; a cash-transaction note alone invalidates the assessment.
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      Income Tax

      Since AO has not conclusively proved the fact that there is an...

      AO Fails to Prove Arrangement with AE; Section 80IA(10) Deduction Disallowance Deemed Unjustified.

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      Income TaxJuly 27, 2015Case LawsAT
      Since AO has not conclusively proved the fact that there is an arrangement between assessee and its AE by which the transactions were so arranged as to produce more than the ordinary profits in the hands of assessee, disallowance of part deduction claimed by applying the provisions of section 80IA(10), in our view is not justified - AT
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