Loading...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Keyword Search :
AI Tools : New
Ask tax questions in natural language. Powered by AI trained on the TaxTMI legal database. Use AI Tools ➞
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
    6. Text Search
  6. The system will try to fetch results that contains ALL your words.
  7. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
    8. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Highlights - Adv. Search ❯
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ---- ❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ---- ❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    August 29, 2026   Case Laws Income Tax
    Share-capital issue expenses include Registrar fees, allowing preliminary-expenditure amortisation where shares are issued to a holding company.
    August 29, 2026   Case Laws Income Tax
    Decoding seized numerical entries requires reasoned evidentiary support; unsupported multipliers fail, while duplicate taxation and financial incapaci...
    August 29, 2026   Case Laws Income Tax
    Revisionary jurisdiction cannot replace an Assessing Officer's considered view after full disclosure and examination during assessment.
    August 29, 2026   Case Laws Income Tax
    Revision for alleged lack of inquiry fails where assessment records show inquiries, application of mind, and no identified defects.
    August 29, 2026   Case Laws Income Tax
    Interest on excess self-assessment tax refunds runs from payment where appellate relief reduces tax ultimately chargeable.
    August 29, 2026   Case Laws Income Tax
    Advance-tax appeal admission requires examination of claimed absence of taxable income before dismissal or remand
    August 29, 2026   Case Laws Income Tax
    Tax-motivated capital loss remains allowable where share transactions are genuine and lack evidence of an artificial arrangement.
    August 29, 2026   Case Laws Income Tax
    Transfer-pricing rules cannot benchmark independently agreed royalty payments without evidence of an associated-enterprise relationship, requiring del...
    August 29, 2026   Case Laws Income Tax
    Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
    August 29, 2026   Case Laws Income Tax
    Cost-to-cost reimbursements exclude value-free third-party expenses from transfer-pricing adjustment, while unsupported salary cross-charges remain ad...
    August 29, 2026   Case Laws Income Tax
    DRP directions bind assessment proceedings, barring protective AMP adjustments and methodology changes through rectification in transfer-pricing asses...
    August 29, 2026   Case Laws Income Tax
    Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
    August 29, 2026   Case Laws Income Tax
    TDS-default expenditure requires proof of prior-year disallowance; unnotified entities cannot claim exemption despite pending writ proceedings.
    August 29, 2026   Case Laws Income Tax
    Double addition of goodwill cannot stand where its book write-off was already added back; depreciation disallowance remained.
    August 29, 2026   Case Laws Income Tax
    Search-related assessment framework governs post-search proceedings, while evidentiary burdens shape loan, cash, and transfer-pricing adjustments.
    August 29, 2026   Case Laws Income Tax
    Trade discount characterisation prevails over tax statement labels when invoice reconciliation establishes the receipts' true nature.
    August 29, 2026   Case Laws Income Tax
    Interest on enhanced compensation remains taxable, while the statutory half deduction must reduce taxable income.
    August 29, 2026   Case Laws Customs
    Reasonable Time for Drawback Recovery invalidates delayed recovery and bank-account attachment where fraud or suppression is not alleged.
    August 29, 2026   Case Laws Customs
    Customs reclassification requires technical evidence; unsupported rejection of mixed-fibre fabric classification cannot sustain duty, interest or pena...
    August 29, 2026   Case Laws Companies Law
    Territorial jurisdiction under Article 226(2) requires substantial nexus and forum convenience, directing the investigation challenge to Mumbai.
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Open Link
Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
August 29, 2026   Case Laws Income Tax
Share-capital issue expenses include Registrar fees, allowing preliminary-expenditure amortisation where shares are issued to a holding company.
August 29, 2026   Case Laws Income Tax
Decoding seized numerical entries requires reasoned evidentiary support; unsupported multipliers fail, while duplicate taxation and financial incapacity defeat additions.
August 29, 2026   Case Laws Income Tax
Revisionary jurisdiction cannot replace an Assessing Officer's considered view after full disclosure and examination during assessment.
August 29, 2026   Case Laws Income Tax
Revision for alleged lack of inquiry fails where assessment records show inquiries, application of mind, and no identified defects.
August 29, 2026   Case Laws Income Tax
Interest on excess self-assessment tax refunds runs from payment where appellate relief reduces tax ultimately chargeable.
August 29, 2026   Case Laws Income Tax
Advance-tax appeal admission requires examination of claimed absence of taxable income before dismissal or remand
August 29, 2026   Case Laws Income Tax
Tax-motivated capital loss remains allowable where share transactions are genuine and lack evidence of an artificial arrangement.
August 29, 2026   Case Laws Income Tax
Transfer-pricing rules cannot benchmark independently agreed royalty payments without evidence of an associated-enterprise relationship, requiring deletion of disallowance.
August 29, 2026   Case Laws Income Tax
Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental data.
August 29, 2026   Case Laws Income Tax
Cost-to-cost reimbursements exclude value-free third-party expenses from transfer-pricing adjustment, while unsupported salary cross-charges remain adjusted.
August 29, 2026   Case Laws Income Tax
DRP directions bind assessment proceedings, barring protective AMP adjustments and methodology changes through rectification in transfer-pricing assessments.
August 29, 2026   Case Laws Income Tax
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and margin issues.
August 29, 2026   Case Laws Income Tax
TDS-default expenditure requires proof of prior-year disallowance; unnotified entities cannot claim exemption despite pending writ proceedings.
August 29, 2026   Case Laws Income Tax
Double addition of goodwill cannot stand where its book write-off was already added back; depreciation disallowance remained.
August 29, 2026   Case Laws Income Tax
Search-related assessment framework governs post-search proceedings, while evidentiary burdens shape loan, cash, and transfer-pricing adjustments.
August 29, 2026   Case Laws Income Tax
Trade discount characterisation prevails over tax statement labels when invoice reconciliation establishes the receipts' true nature.
August 29, 2026   Case Laws Income Tax
Interest on enhanced compensation remains taxable, while the statutory half deduction must reduce taxable income.
August 29, 2026   Case Laws Customs
Reasonable Time for Drawback Recovery invalidates delayed recovery and bank-account attachment where fraud or suppression is not alleged.
August 29, 2026   Case Laws Customs
Customs reclassification requires technical evidence; unsupported rejection of mixed-fibre fabric classification cannot sustain duty, interest or penalties.
August 29, 2026   Case Laws Companies Law
Territorial jurisdiction under Article 226(2) requires substantial nexus and forum convenience, directing the investigation challenge to Mumbai.

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

Home › Highlights › Income Tax › 2016 › January, 2016 › This
Back

All Highlights

whatsapp Join Channel
Showing Results for : Reset Filters
Income Tax

Transfer pricing adjustment - Early or late realization of sale...

Transfer Pricing Adjustment for Sale Proceeds Timing Is Incidental, Not Separate; Interest on Delayed Proceeds Not International Transaction.

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Print Options

Income Tax January 11, 2016 Case Laws AT
Transfer pricing adjustment - Early or late realization of sale proceeds is only incidental to transaction of sale, but not a separate transaction in nature. - the impugned transaction of interest on delayed realization of sale proceeds is not international transaction - AT
View Source View

Topics

Acts Income Tax
Next ➔