Residential property investment under Section 54F remains eligible despite delayed completion, possession or registration beyond the taxpayer's contro...
Royalty benchmarking under TNMM prevails where domestic rates lack reliable comparability for export transactions and technical know-how use.
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Statutory approval under reassessment rules is jurisdictional; sanction by an incompetent authority invalidates the notice and reassessment.
Insurance compensation adjusted against fire loss cannot be separately taxed, and the consequential concealment penalty fails.
Securitisation trust pass-through taxation applies where investors lack voluntary common design and retain revocation rights over contributions.
Mandatory prior notice for bank-account attachment requires release where the assessee was not informed before recovery action.
Bona fide cash accounting for unpaid loan interest permits exclusion of accrued but unrealised income when consistently disclosed.
Doctrine of election barred inconsistent ownership claims, while testamentary office permission created no life interest or possessory right.
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Aluminium formwork classification turns on its on-site shuttering function, supporting treatment as aluminium structures rather than moulds.
Aluminium formwork used as concrete shuttering is classified as aluminium structures, not as moulds for concrete articles.
Customs valuation: proven under-invoicing sustains duty and confiscation, while provisional assessments require lawful finalisation before consequenti...
Sole or principal use classification placed imported floating seals under machinery-parts heading, defeating extended-period customs consequences.
Roasted nut classification follows specific Chapter 20 entries, while preferential duty depends on establishing prescribed originating status.
Semi-manufactured gold classification under Heading 7108 permits conditional ASEAN tariff preference without displacing separate import-policy restric...
Section 7 insolvency admission proceeds despite unfinalised compromise proposals, settlement talks and pending counterclaims where financial debt and ...
Proportional disciplinary suspension requires hearings on unrelated assignments; creditor committees retain discretion to replace resolution professio...
Limitation for insolvency applications defeated proceedings despite valid partner authorisation and advances qualifying as financial debt.