Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Allowability of Interest expenses @21.3% - unsecured redeemable cumulative non-convertible debentures - AO has compared the rate of interest paid on unsecured redeemable cumulative non-convertible debentures with the rate of interest at which the secured loan was borrowed by the assessee, which is wholly erroneous - However, matter restored back to determining the arm’s length interest rate considering risk and other factors - AT
Allowability of Interest expenses @21.3% - unsecured redeemable cumulative non-convertible debentures - AO has compared the rate of interest paid on unsecured redeemable cumulative non-convertible debentures with the rate of interest at which the secured loan was borrowed by the assessee, which is wholly erroneous - However, matter restored back to determining the arm’s length interest rate considering risk and other factors - AT
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