Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
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...
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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