Just a moment...

Top
Help
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback

Contact Us At :

E-mail: [email protected]

Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
  6. Text Search
  7. The system will try to fetch results that contains ALL your words.
  8. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
  9. Text Search
Add to...
You have not created any category. Kindly create one to bookmark this item!
Create New Category
Hide
Title :
Description :
❮❮ Hide
Default View
Expand ❯❯
Close ✕
🔎 Highlights - Adv. Search
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws----
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ----
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ----
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    Purchase returns accounting discrepancy treated as excess purchases; s.270A "misreporting" penalty rejected and deleted on appeal
    Cash received under agreement to sell above threshold: section 271D penalty for alleged section 269SS breach set aside.
    Limited scrutiny of share premium and share application money: Section 68 addition and assessment quashed for invalid 143(2) notice
    Tax demand created later by s.154 rectification after "nil" assessment; s.220(2) interest deleted until fresh s.156 notice served.
    Flat-sale revenue recognition timing under project completion vs 25% completion threshold; addition deleted to avoid double taxation.
    Non-resident employee's foreign assignment salary for services entirely outside India held not accruing in India u/s5(2)(b)
    Transfer pricing on AE SBLC guarantee fees and loan interest benchmarked correctly; NBFC loan cash-credit addition deleted, R&D deduction allowed
    Cost-to-cost reimbursements for AE's marketing events and year-end service provisions: no TP mark-up, adjustment deleted; 115JB recompute
    Demonetisation cash deposits and s69 addition: whether already covered by s245D(4) settlement income; double-tax bar upheld, appeal dismissed
    Intra-group management service fees benchmarking under "Other Method": cost-plus markups accepted; Nil arm's-length price adjustment deleted.
    Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
    Property purchases using appellant's funds held benami u/s2(9)(A); attachment upheld despite no cross-examination, appeals dismissed.
    Anti-dumping final findings challenged for unfair procedure; business impact didn't create cause of action, so writ dismissed for no jurisdiction.
    COFEPOSA preventive detention for alleged abetment of organised smuggling upheld, as order cited repeated role and no procedural flaw
    Imported "penetrating oil-60" classification dispute: lubricating preparation (CTH 3403 9900) vs adulterated diesel (CTH 2710 1990); appeals allowed
    Corn silk extract powder import classification as vegetable extract (Heading 1302) upheld; Heading 2106 rejected, exemption Sr.54 allowed
    Import classification of roasted areca, cashew, almond and pista nuts; areca treated raw, preferential BCD needs origin proof
    External forensic audit for lender banks: conflict-linked consultant, non-CA sign-off and delayed report voided under RBI clause 4.1
    Civil suit challenging allegedly oppressive EOGM and related corporate actions held barred u/ss 242/430; plaint dismissed.
    Defective share certificate and register rectification u/s 59: bid to compel fresh issuance rejected, appeal dismissed
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

Back

All Highlights

whatsapp Join Channel
Showing Results for : Reset Filters

Computational errors in assessment were held rectifiable as...

Transfer pricing on management services, software reimbursements and captive power rates; s.80-IA/MAT assessment errors corrected, adjustments deleted

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Income Tax December 20, 2025 Case Laws AT
Computational errors in assessment were held rectifiable as apparent from record, since deduction under s.80-IA was disallowed twice to the extent already added via TP adjustment, Chapter VI-A deduction and MAT credit were wrongly computed, and income was taken from s.143(1) intimation instead of revised return; AO was directed to rectify and recompute demand/refund. In TP for management support services, functionally dissimilar/government and credit-rating comparables were excluded, resulting in assessee's margin being at arm's length; TP adjustment was deleted. Reimbursement of software costs from AEs at cost was held not to warrant mark-up; adjustment was deleted. SEB rate (not IEX) was adopted for captive power transfers; related TP adjustments were deleted. Absence of exempt income barred s.14A disallowance (including under MAT); disallowance was deleted. Enhanced s.80-IA claim and interest on receivables were remanded for verification. - ITAT

Topics

Acts Income Tax