Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
The High Court held that the Bright Line Test could not be adopted for transfer pricing because it is not provided under the Income-tax Act, 1961 or the Rules and is alien to the statutory scheme; the proposed question was rejected. It also declined to entertain the royalty adjustment questions, noting that the need for any transfer pricing adjustment, the computation method, and the arm's length price had already been decided in the assessee's own cases, with no contrary Supreme Court ruling shown. The exclusion of Febulka Advertising Pvt. Ltd. as a comparable was treated as a factual finding based on its different business and incomplete public data, beyond interference under section 260A. The appeal was dismissed.
The High Court held that the Bright Line Test could not be adopted for transfer pricing because it is not provided under the Income-tax Act, 1961 or the Rules and is alien to the statutory scheme; the proposed question was rejected. It also declined to entertain the royalty adjustment questions, noting that the need for any transfer pricing adjustment, the computation method, and the arm's length price had already been decided in the assessee's own cases, with no contrary Supreme Court ruling shown. The exclusion of Febulka Advertising Pvt. Ltd. as a comparable was treated as a factual finding based on its different business and incomplete public data, beyond interference under section 260A. The appeal was dismissed.
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