Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Assessing Officer's suo motu computation of net profit based solely on a survey statement without rejecting books or affording explanation was held arbitrary and the addition deleted. Alleged deemed sales of four parking spaces lacked contemporaneous stock records; Tribunal remitted the matter for fresh verification and afforded the assessee a hearing. Interest on unsecured loans capitalised as part of Work in Progress for a real estate developer was treated as business expenditure (acquisition/holding of land as inventory) and the AO's disallowance of such capitalised interest was reversed.
Assessing Officer's suo motu computation of net profit based solely on a survey statement without rejecting books or affording explanation was held arbitrary and the addition deleted. Alleged deemed sales of four parking spaces lacked contemporaneous stock records; Tribunal remitted the matter for fresh verification and afforded the assessee a hearing. Interest on unsecured loans capitalised as part of Work in Progress for a real estate developer was treated as business expenditure (acquisition/holding of land as inventory) and the AO's disallowance of such capitalised interest was reversed.
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