Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
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 ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
TP Adjustment - TPO rejected the ‘entity-level’ benchmarking done by assessee, instead made ‘unit-level’ comparison i.e. PLI of each unit was compared with the PLI of external comparables - 'principle of res judicata' OR ‘principle of consistency' - the uniform rate agreed by assessee with AEs is certainly a rate at entity-level which has no connection or linkage with individual units. - AT
TP Adjustment - TPO rejected the ‘entity-level’ benchmarking done by assessee, instead made ‘unit-level’ comparison i.e. PLI of each unit was compared with the PLI of external comparables - 'principle of res judicata' OR ‘principle of consistency' - the uniform rate agreed by assessee with AEs is certainly a rate at entity-level which has no connection or linkage with individual units. - AT
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