Jurisdictional sanction requirements bar reassessment when approval comes from an authority lacking statutory competence under the applicable framewor...
Recorded sales receipts cannot be reassessed as unexplained cash credits, eliminating the basis for consequential alleged commission expenditure addit...
Sufficient cause for delayed income-tax appeals requires bona fide diligence; unsubstantiated counsel illness and assessee inaction defeat condonation...
TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
HC dismissed the revenue's ALP adjustment in respect of advertising, marketing and promotional (AMP) expenses, holding that the addition was precluded by the HC's prior decision in the taxpayer's own case, which was followed by the tribunal; consequently no substantive or protective addition could be sustained on this score. Separately, HC held that the amendment to section 14A of the Act read with Rule 8D cannot be construed as retrospective where it operates to alter the pre-existing legal position despite being framed "for removal of doubts"; such language does not permit retroactive application to change settled law.
HC dismissed the revenue's ALP adjustment in respect of advertising, marketing and promotional (AMP) expenses, holding that the addition was precluded by the HC's prior decision in the taxpayer's own case, which was followed by the tribunal; consequently no substantive or protective addition could be sustained on this score. Separately, HC held that the amendment to section 14A of the Act read with Rule 8D cannot be construed as retrospective where it operates to alter the pre-existing legal position despite being framed "for removal of doubts"; such language does not permit retroactive application to change settled law.
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TaxTMI 
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