Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Transfer pricing on back-to-back project execution was held to be benchmarked under the CUP method rather than TNMM because the assessee acted as a project office for the foreign principal and the relevant transactions were direct services to the associated enterprise. The Tribunal treated the joint venture structure as an administrative vehicle, noted that the project results and related financials were already recorded and taxed in India, and found no realistic profit-shifting concern where the operations and reimbursements were domestic in nature. On that basis, it affirmed deletion of the transfer pricing adjustment and rejected the Revenue's challenge.
Transfer pricing on back-to-back project execution was held to be benchmarked under the CUP method rather than TNMM because the assessee acted as a project office for the foreign principal and the relevant transactions were direct services to the associated enterprise. The Tribunal treated the joint venture structure as an administrative vehicle, noted that the project results and related financials were already recorded and taxed in India, and found no realistic profit-shifting concern where the operations and reimbursements were domestic in nature. On that basis, it affirmed deletion of the transfer pricing adjustment and rejected the Revenue's challenge.
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