Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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Exempt dividend income earned by assessee. Interest-free owned funds exceeded investments in tax-free securities, disallowance u/r 8D(2)(ii) not warranted. For Rule 8D(2)(iii) disallowance, only investments yielding exempt income to be considered, recomputation directed. No adjustment for section 14A disallowance to book profits u/s 115JB, as not proposed in draft order or directed by DRP. Discount to pre-paid distributors not subject to TDS u/s 194H, no disallowance u/s 40(a)(ia). Depreciation on 3G spectrum allowed u/s 32(1)(ii). Brand royalty payment to AE remanded to TPO/AO for fresh benchmarking. Reimbursement of expenses to AE remanded for substantiation. Additional TDS credit to be granted as per law after verification. Legal terminology from Income Tax Act and Rules used.
Exempt dividend income earned by assessee. Interest-free owned funds exceeded investments in tax-free securities, disallowance u/r 8D(2)(ii) not warranted. For Rule 8D(2)(iii) disallowance, only investments yielding exempt income to be considered, recomputation directed. No adjustment for section 14A disallowance to book profits u/s 115JB, as not proposed in draft order or directed by DRP. Discount to pre-paid distributors not subject to TDS u/s 194H, no disallowance u/s 40(a)(ia). Depreciation on 3G spectrum allowed u/s 32(1)(ii). Brand royalty payment to AE remanded to TPO/AO for fresh benchmarking. Reimbursement of expenses to AE remanded for substantiation. Additional TDS credit to be granted as per law after verification. Legal terminology from Income Tax Act and Rules used.
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