Transfer-pricing method selection remains factual where TNMM is rule-compliant, leaving no substantial question of law for review.

Reopening after four years fails where audit objections merely trigger re-examination of records already assessed without fresh tangible material.

TDS credit for actual deduction cannot be denied solely because the deductor failed to deposit or report tax.

Depreciation on acquired brand-name and distribution rights is allowable as business or commercial intangible assets under Section 32.

Ind AS and ICDS tax computation principles prevent taxation of notional income and unsupported double disallowances.

Capital gains on transferable development rights apply where surrendered land provides an ascertainable acquisition cost for the rights.

Dividend distribution tax treaty-rate claims await Supreme Court guidance before fresh adjudication of India-Netherlands DTAA applicability.

Reasoned adjudication of reassessment jurisdictional objections must precede merits review where foundational defects may invalidate the reassessment.

Concessional corporate tax rate applies despite an incorrect return provision reference where turnover eligibility is otherwise satisfied.

Faceless reassessment jurisdiction remains valid, while ex parte additions require fresh appellate review where natural justice demands hearing.

Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...

Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...

Bad-debt deductions for written-off commodity receivables were allowed, while windmill-profit expense allocation required fresh factual examination.

Foreign-leg travel reimbursement: binding interim restraint prevented retrospective employer default and eliminated consequential tax-deduction penalt...

Rejection of unreliable liquor-trade books justified profit estimation and separate taxation of omitted advertisement-display business receipts.

Specific penalty charges under section 270A are mandatory; vague notices for under-reporting or misreporting cannot sustain penalties.

Actual redemption consideration governs preference-share capital gains where no deeming rule permits substitution with equity-share valuation.

Non-cash share consideration escapes share-premium taxation, while bad debts and unsupported prior-period claims receive differing treatment.

Transfer pricing tolerance rules remove adjustments where software and advertising service prices fall within prescribed ranges.

Re-import exemption excludes FTWZ-to-DTA clearance when petroleum equipment returns under a fresh essentiality certificate for a new contract.