Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Advance rulings under Section 95(a) are prospective; where all contractual acts, possession and payment were completed before filing, the transaction is not a supply "being undertaken or proposed" and therefore falls outside the AAR's permissible scope. The authority found that the assignment of leasehold rights and related charges were fully executed before the application, so questions on taxability of land development charges and eligibility of input tax credit could not be determined by advance ruling. Consequence: the application was held not maintainable and the AAR declined to decide the substantive tax issues.
Advance rulings under Section 95(a) are prospective; where all contractual acts, possession and payment were completed before filing, the transaction is not a supply "being undertaken or proposed" and therefore falls outside the AAR's permissible scope. The authority found that the assignment of leasehold rights and related charges were fully executed before the application, so questions on taxability of land development charges and eligibility of input tax credit could not be determined by advance ruling. Consequence: the application was held not maintainable and the AAR declined to decide the substantive tax issues.
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TaxTMI 
TaxTMI 
of 4913 
