Approved gratuity fund provisions remain deductible despite general actual-payment requirements, preventing revision of the allowed gratuity deduction...
Verification of intangible software expenditure and duplicated disallowances requires record-based reassessment before depreciation and income computa...
Cash receipt aggregation requires a single transaction, event or occasion; separate partner capital contributions cannot attract cash-receipt penaltie...
The HC declined to entertain the petition challenging the Tribunal's decision under Section 254(2) regarding TP adjustment for guarantee fees paid to an Associated Enterprise. The Court noted that the Tribunal had decided Ground No.4 in favor of the Assessee based on a precedent from the Gujarat HC [2018] that confirmed a similar ruling for an earlier assessment year (2009-10). The Court determined it would be an academic exercise to evaluate the Tribunal's power to recall its order under Section 254(2) when the HC had already approved similar findings in the previous assessment year, thereby implicitly validating the Tribunal's conclusion rejecting the upward TP adjustment of guarantee fees.
The HC declined to entertain the petition challenging the Tribunal's decision under Section 254(2) regarding TP adjustment for guarantee fees paid to an Associated Enterprise. The Court noted that the Tribunal had decided Ground No.4 in favor of the Assessee based on a precedent from the Gujarat HC [2018] that confirmed a similar ruling for an earlier assessment year (2009-10). The Court determined it would be an academic exercise to evaluate the Tribunal's power to recall its order under Section 254(2) when the HC had already approved similar findings in the previous assessment year, thereby implicitly validating the Tribunal's conclusion rejecting the upward TP adjustment of guarantee fees.
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TaxTMI 
TaxTMI 
of 4925 
