Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Claim for deduction under Section 80-IA is rejected by Revenue because agreement was with a corporate and the fuel farm lay outside airport premises; court finds the agreement was with a statutory airport authority and that the fuel farm is an integral component of airport operations, so the requisite conditions for the 80-IA benefit are satisfied and the deduction is allowable. On interest deductibility under Section 36(1)(iii) for hedge (swap) transactions, the Tribunal's application of the controlling Supreme Court precedent supports allowance of the interest expense, and Revenue does not contest that applicability.
Claim for deduction under Section 80-IA is rejected by Revenue because agreement was with a corporate and the fuel farm lay outside airport premises; court finds the agreement was with a statutory airport authority and that the fuel farm is an integral component of airport operations, so the requisite conditions for the 80-IA benefit are satisfied and the deduction is allowable. On interest deductibility under Section 36(1)(iii) for hedge (swap) transactions, the Tribunal's application of the controlling Supreme Court precedent supports allowance of the interest expense, and Revenue does not contest that applicability.
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