Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Benami property exclusion from the insolvency estate: Benami Act proceedings preclude IBC tribunals from reopening attachments or treating such assets...
Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
Transfer pricing adjustments challenged: internal Comparable Uncontrolled Price benchmarking for interest on loans to associated enterprises upheld and ad hoc 100 basis point forex risk addition rejected, resulting in deletion of the upward interest adjustment. Notional interest on overdue receivables treated as part of the principal international sale transaction and deleted. Depreciation claim on goodwill arising from amalgamation sustained for lack of commercial substance challenge. Allocation of common expenses to incentivised units accepted where supported by separate books. Weighted deduction under research provisions not confined to the amount in approval form. Disallowances under interest allocation and Rule 8D deleted; commission to non resident agents not taxable in India absent business connection.
Transfer pricing adjustments challenged: internal Comparable Uncontrolled Price benchmarking for interest on loans to associated enterprises upheld and ad hoc 100 basis point forex risk addition rejected, resulting in deletion of the upward interest adjustment. Notional interest on overdue receivables treated as part of the principal international sale transaction and deleted. Depreciation claim on goodwill arising from amalgamation sustained for lack of commercial substance challenge. Allocation of common expenses to incentivised units accepted where supported by separate books. Weighted deduction under research provisions not confined to the amount in approval form. Disallowances under interest allocation and Rule 8D deleted; commission to non resident agents not taxable in India absent business connection.
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