Foreign-currency loan benchmarking follows the loan currency, while export hedging losses qualify as non-speculative business losses.

Delayed initiation of TDS return penalties after nine years rendered the penalty illegal and unsustainable.

Project-development assistance treated as capital, while infrastructure construction costs may be amortised over the concession period.

Delayed trade receivables require separate transfer pricing benchmarking, subject to debt-free status and an appropriate credit period.

Modified returns, MAT book profit limits, and tested-party selection shape transfer pricing treatment of integrated intra-group services.

Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...

Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...

Share valuation method choice protects DCF valuations from replacement with NAV, though projections remain open to scrutiny.

Penalty immunity requires reconsideration where rectification removes the assessment demand and leaves a refund instead.

Under-reporting penalty applies when taxable income is not returned, even if reassessment disclosure is accepted without additions.

Benami RTGS credits unsupported by independent evidence justified attachment, while unproven prejudice defeated the natural justice challenge.

Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...

Brand rate drawback for bus bodies may coexist with DEPB where duplicate duty reimbursement is not established by evidence.

Made-up textile article classification governs triangular umbrella panels, while full customs disclosure prevents extended limitation in classificatio...

Abetment penalties require proof that a Customs Broker representative knowingly facilitated improper importation of prohibited goods.

Actual user conditions prohibit disguised sales of duty-free inputs through arrangements labelled as job work.

Abetment of attempted export requires proven positive assistance or knowledge; penalties cannot rest on unsupported allegations of concealment.

Unsubmitted arbitral award claims are extinguished by approved resolution plans, while court-deposited security remains the corporate debtor's asset.

Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...

Pre-existing operational debt dispute and post-admission settlement led to reversal of CIRP admission and closure of insolvency proceedings.