Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Omission of clause (i) of section 92BA was treated as having retrospective effect, so the reference to the TPO and the transfer pricing adjustment based on specified domestic transactions was held invalid and deleted. Brokerage paid in the ordinary course of a leasing business was allowed under section 37(1) to the extent supported by invoices and tenant details, while the balance was remitted for verification. Receipts such as car parking income, interest on fixed deposits, permission charges and licence fee were held to have a direct nexus with SEZ business and were treated as eligible for deduction under section 80IAB, making their reclassification as income from other sources unsustainable.
Omission of clause (i) of section 92BA was treated as having retrospective effect, so the reference to the TPO and the transfer pricing adjustment based on specified domestic transactions was held invalid and deleted. Brokerage paid in the ordinary course of a leasing business was allowed under section 37(1) to the extent supported by invoices and tenant details, while the balance was remitted for verification. Receipts such as car parking income, interest on fixed deposits, permission charges and licence fee were held to have a direct nexus with SEZ business and were treated as eligible for deduction under section 80IAB, making their reclassification as income from other sources unsustainable.
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