Full and true disclosure governs settlement applications; income cannot be recharacterised under Sections 69B and 115BBE in settlement proceedings
Mandatory DRP directions must shape the final assessment; a post-limitation corrigendum cannot cure the statutory defect.
Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Adequate enquiry limits section 263 revision; shareholder funding and commercially expedient purchases may avoid tax adjustments
Pecuniary jurisdiction for scrutiny notices is mandatory; notice by the wrong officer can invalidate the resulting assessment.
Open-access medical and educational activities outweigh an isolated religious object clause, supporting charitable registration and donation approval
Non-recourse receivables assignment is a sale, not borrowing; alleged discounting charges are not interest for TDS purposes.
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Turnover filters and receivables benchmarking reshape software-services transfer pricing: high-turnover comparables excluded and interest recomputed a...
Consistent depreciation treatment supports computer peripherals, film software libraries and demerged non-compete fees; production costs remain revenu...
Charitable medical relief survives hospital scale, surplus and premium facilities; retrospective registration cancellation and consequential donation ...
Medical relief remains charitable despite premium hospital operations; statutory enquiry focuses on genuine activities and application of income.
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Lease deed stamp duty is revenue expenditure when it secures business use, preventing later capitalisation, amortisation, or depreciation claims.
Combined TNMM benchmarking bars separate royalty and GAM adjustments when those costs are embedded in the tested segment's operating base
Reasonable cause limits transfer-pricing penalties, while appellate enhancement cannot extend proceedings to transactions never included in initiation
Statutory admission screening limits respondent intervention, deferring maintainability and jurisdiction objections to the post-admission hearing.
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Interest forms part of financial debt when acknowledged through conduct, affecting Section 7 threshold assessment for inter corporate deposits