Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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...
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Transfer pricing adjustment for software development and related support services - Comparables deselected due to functional dissimilarity. TPO directed to exclude certain companies. Transfer pricing adjustment for interest on receivables - TPO's calculation of interest on entire closing balance incorrect. TPO instructed to compute interest based on delay for each invoice beyond grace period after examining agreements or market practice. Employee's PF contribution disallowed for non-compliance with statutory deposit timelines. No long-term capital gain on amount credited to capital reserve pursuant to merger, covered u/s 47(vi). Double addition in computation corrected. Finance cost disallowance deleted as no transfer pricing adjustment proposed. Advance tax credit and TDS credit from merged entity directed to be allowed based on evidence.
Transfer pricing adjustment for software development and related support services - Comparables deselected due to functional dissimilarity. TPO directed to exclude certain companies. Transfer pricing adjustment for interest on receivables - TPO's calculation of interest on entire closing balance incorrect. TPO instructed to compute interest based on delay for each invoice beyond grace period after examining agreements or market practice. Employee's PF contribution disallowed for non-compliance with statutory deposit timelines. No long-term capital gain on amount credited to capital reserve pursuant to merger, covered u/s 47(vi). Double addition in computation corrected. Finance cost disallowance deleted as no transfer pricing adjustment proposed. Advance tax credit and TDS credit from merged entity directed to be allowed based on evidence.
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