Site restoration deduction upheld; reassessment quashed for lack of reasons and notice beyond limitation

Retrospective reassessment amendment kept notice challenges open on remand, with liberty to contest the new provision.

Decretal interest as judgment debt cannot be subjected to TDS deduction by the judgment debtor absent decree authorisation.

Compensatory interest for wrongful retention of seized KVPs and IVPs allowed until release, with simple interest on arrears.

Co-operative bank TDS exemption turned on binding CBDT note, while the restrictive proviso survived constitutional challenge.

Black Money Act limitation and TOLA extensions: assessment quashed as time-barred because the notifications did not apply.

Royalty and FIS/FTS treatment of database recharge and seconded employee reimbursements under India-USA DTAA held non-taxable

Article 8 shipping receipts from feeder vessels and slot hire held covered by the DTAA, not separately taxed.

Arrears of superannuation fund perquisites qualify for salary relief, and Rule 21A applies to the claim.

Burden of proof in penalty cases defeats cash-loan penalties based only on third-party seized papers

Royalty and management support service adjustments fail where costs were recovered and aggregated TNMM benchmarking applied.

Transfer pricing adjustments remanded for fresh review of intra-group services, sensor assembling method and comparables analysis

Foreign asset disclosure in a substituted return can defeat penalty for an earlier omission when assessment accepts it.

Comparability filters in TNMM require upfront R&D screening and broadly similar turnover scales for software services.

Functional comparability in wholesale auto-component trading excludes retail and after-sales comparables, deleting transfer pricing adjustments

Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...

Pass-through LLC self-dealing defeats transfer pricing adjustment; linked receivables and profit recomputation were also deleted.

Transfer pricing comparability: predominantly manufacturing comparables were excluded, and IT support charges were not fixed at nil.

Substantial compliance in transfer pricing documentation defeats penalty for diamond trade record shortfall where arm's length pricing stood accepted

Double taxation through rectification was impermissible where income already shown under proper heads was added again to business income.