Human-probability test defeats political donation deduction where banking records mask accommodation-entry fund layering and evidence shows non-genuin...
Commercial property status protects capital-gains exemption when residential-house ownership limits are tested, while agricultural-land character gove...
Investigation deposits refunded after failed customs demands fall outside the statutory appellate pre-deposit interest regime and may attract compensa...
Resolution plan finality extinguishes unquantified operational-creditor claims and pending proceedings unless the approved plan expressly preserves th...
TP adjustment - TPO accepted ALP based on TNMM but sought separate benchmarking of notional interest on the outstanding receivables - if the impact of extended credit period on working capital was factored in the pricing/profitability, then any credit period allowed to AE gets subsumed in TNMM and there is no tax leakage or evasive tactics adopted by the taxpayer while transacting with the AE, and there is no need for a separate benchmarking
TP adjustment - TPO accepted ALP based on TNMM but sought separate benchmarking of notional interest on the outstanding receivables - if the impact of extended credit period on working capital was factored in the pricing/profitability, then any credit period allowed to AE gets subsumed in TNMM and there is no tax leakage or evasive tactics adopted by the taxpayer while transacting with the AE, and there is no need for a separate benchmarking
Note: It is a system-generated summary and is for quick reference only.