Natural justice in insolvency-professional discipline requires disclosed material; notices based on extraneous material and ignored defences are vitia...
Development rights transfers treated as immovable property, while construction abatement applies and repeated non-payment permits extended service-tax...
Income Disclosure Scheme immunity and search-material requirements barred further share-transaction additions in unabated assessments under section 15...
Transfer pricing adjustments on corporate guarantee commission and interest on convertible loans were rejected because identical issues were previously decided in favour of the taxpayer by the ITAT; outcome: adjustments deleted. Reimbursement of expenses was held at arm's length on documentary proof and past ITAT precedent; outcome: adjustment denied. Sale of goods to an AE benchmarked using Compustat North America fell within the 3% safe harbour margin and the adjustment was dismissed. Three rejected comparables were accepted as functionally and jurisdictionally comparable; outcome: AO/TPO rejection overturned. DIANE database search for a later year failed Rule 10CA requirements; outcome: comparable search rejected. Claim for weighted R&D deduction limited to expenditure approved by the competent authority was upheld; outcome: deduction restricted to DSIR-approved quantum.
Transfer pricing adjustments on corporate guarantee commission and interest on convertible loans were rejected because identical issues were previously decided in favour of the taxpayer by the ITAT; outcome: adjustments deleted. Reimbursement of expenses was held at arm's length on documentary proof and past ITAT precedent; outcome: adjustment denied. Sale of goods to an AE benchmarked using Compustat North America fell within the 3% safe harbour margin and the adjustment was dismissed. Three rejected comparables were accepted as functionally and jurisdictionally comparable; outcome: AO/TPO rejection overturned. DIANE database search for a later year failed Rule 10CA requirements; outcome: comparable search rejected. Claim for weighted R&D deduction limited to expenditure approved by the competent authority was upheld; outcome: deduction restricted to DSIR-approved quantum.
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