Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Royalty on export sales required fresh examination because the Tribunal found that the source of income must be distinguished from the source of receipt, but the Assessing Officer had not fully verified where the export contracts were concluded or whether the royalty was taxed in another jurisdiction; the issue was remanded without final merits adjudication. Management support services were held not to be fee for technical services under the India-Singapore DTAA because that agreement operated independently from the royalty/licensing arrangement, and the assessee succeeded on that issue for all years. On reimbursement of expenses, the DRP lacked power under section 144C(8) to direct further enquiry and fresh determination by the Assessing Officer, so those directions were invalid and the related addition for AY 2022-23 was deleted.
Royalty on export sales required fresh examination because the Tribunal found that the source of income must be distinguished from the source of receipt, but the Assessing Officer had not fully verified where the export contracts were concluded or whether the royalty was taxed in another jurisdiction; the issue was remanded without final merits adjudication. Management support services were held not to be fee for technical services under the India-Singapore DTAA because that agreement operated independently from the royalty/licensing arrangement, and the assessee succeeded on that issue for all years. On reimbursement of expenses, the DRP lacked power under section 144C(8) to direct further enquiry and fresh determination by the Assessing Officer, so those directions were invalid and the related addition for AY 2022-23 was deleted.
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