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    Revisional relief for omitted charitable-trust capital-gains claims extends to fixed-deposit reinvestment where disclosure was complete.
    Subsisting reasons to believe fail when appellate relief removes every subsequent-year foundation for reassessment; the notice was quashed.
    Reason to believe in reassessment requires a live material nexus; unrelated allegations and later law cannot sustain reopening.
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    Intra-group service pricing adjustment deleted after arm's length price was set at nil without sustainable basis.
    Transfer-pricing benchmarking requires proven COVID costs, consistent TNMM classifications, and reliable internal CUP comparability before adjustments...
    Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
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    Assessment jurisdiction requires valid statutory transfer and timely scrutiny notice; administrative reassignment cannot sustain proceedings.
    TDS on statutory market fees and pass-through procurement payments did not trigger contract withholding disallowance.
    Binding Dispute Resolution Panel directions invalidate non-conforming assessments, while ad hoc nil pricing of intra-group services fails.
    Electronic service of DRP directions triggers assessment limitation, making a belated final assessment time-barred and beyond jurisdiction.
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    Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
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    Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
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This case discusses various issues related to the income tax...

Tax Rulings: School Expense Disallowances, Limited Exempt Income Disallowance, and Deferred Payment Commission Upheld.

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Income Tax November 6, 2024 Case Laws AT
This case discusses various issues related to the income tax assessment of a bank. The key points are: Disallowance of expenditure incurred for reservation of seats in schools for employees' children was upheld based on a favorable High Court decision. Disallowance u/s 14A for exempt income was restricted to 1% of exempt income in line with earlier years. Broken period interest paid on securities constituting stock-in-trade was allowed as deduction following a High Court ruling. Interest on securities was taxable only on due basis, not accrual basis, adhering to the accounting method. Loss on revaluation of investments held as stock-in-trade was allowed based on RBI guidelines and favorable High Court decisions. Contribution to pension fund exceeding statutory limits was disallowed u/s 40A(9) following a High Court judgment. The eligibility of the bank to claim deduction u/s 36(1)(viii) for special reserve was remitted back for examination. Deferred payment guarantee commission was held taxable when guarantee was issued and commission received, following precedents. Disallowance of depreciation on leased assets was confirmed. Recovery of bad debts, where no deduction was claimed earlier, was remitted for fresh examination u/s 41(4). Exclusion of foreign branch income was disallowed for the relevant years, allowing only tax credit under tax.

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Acts Income Tax