Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Penalty paid to RBI for breach of regulatory directions was treated as a regulatory levy and not as expenditure for an offence or infraction of law under Explanation 2 to section 37(1), so the deduction was allowed. CSR expenditure was disallowed because the record did not show that it exceeded the statutory CSR obligation, and prior decisions based on the pre-amendment position did not apply after insertion of Explanation 2. The Tribunal also reiterated that appellate authorities can entertain fresh claims not made before the Assessing Officer, so the bad-debt recovery issue was remitted to the Commissioner (Appeals) and the PSLC taxability issue was remitted to the Assessing Officer for fresh adjudication.
Penalty paid to RBI for breach of regulatory directions was treated as a regulatory levy and not as expenditure for an offence or infraction of law under Explanation 2 to section 37(1), so the deduction was allowed. CSR expenditure was disallowed because the record did not show that it exceeded the statutory CSR obligation, and prior decisions based on the pre-amendment position did not apply after insertion of Explanation 2. The Tribunal also reiterated that appellate authorities can entertain fresh claims not made before the Assessing Officer, so the bad-debt recovery issue was remitted to the Commissioner (Appeals) and the PSLC taxability issue was remitted to the Assessing Officer for fresh adjudication.
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