Limitation for consequential assessments runs from prescribed authority receipt, while verified purchases cannot be disallowed merely for unanswered s...
Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Depositor-protection proceedings prevail over corporate insolvency, while liquidators may recover chit receivables using copies of seized company reco...
Transfer Pricing Adjustments - The Tribunal reaffirmed the primacy of the TNMM over CUP for benchmarking certain types of transactions, especially when comparable data for CUP is not readily available or applicable. - The ruling emphasized the reduced rate of taxation on interest income from foreign currency loans under specific conditions, thereby clarifying the applicability of section 115A over normal tax rates. - The allowance of deductions under section 44C was confirmed, highlighting the importance of adhering to the statutory limits and maintaining proper documentation to support such claims. - Lastly, the Tribunal's interpretation of the India-Canada DTAA in the context of taxability of interest on income tax refunds signals a broader understanding of DTAAs' provisions, particularly regarding the exemptions available to non-residents.
Transfer Pricing Adjustments - The Tribunal reaffirmed the primacy of the TNMM over CUP for benchmarking certain types of transactions, especially when comparable data for CUP is not readily available or applicable. - The ruling emphasized the reduced rate of taxation on interest income from foreign currency loans under specific conditions, thereby clarifying the applicability of section 115A over normal tax rates. - The allowance of deductions under section 44C was confirmed, highlighting the importance of adhering to the statutory limits and maintaining proper documentation to support such claims. - Lastly, the Tribunal's interpretation of the India-Canada DTAA in the context of taxability of interest on income tax refunds signals a broader understanding of DTAAs' provisions, particularly regarding the exemptions available to non-residents.
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