Appeals remitted for fresh adjudication; s.80AB (effective 01-04-1981) governs years, s.80I deductions to be read with s.32AB

Reopening assessments quashed for AY 2016-19 for lack of disclosed reasons, denial of hearing; remit for fresh s.148A(d) order

Revenue appeal dismissed; taxpayer's assessments upheld, rejects presumptive taxation under s.44AD, sustains individual adjudication and allows ss.80H...

Section 68: Firm not liable for partners' recorded capital; investigate partner individually for genuineness of funds, addition annulled

DCF valuation under s.56(2)(viib) respected; revenue's addition rejected without proof of manipulated inputs or mala fides

Revenue appeal dismissed; undisclosed commission addition upheld at 0.10% of turnover after remand and sworn statement relied upon

Partly allowed appeal: adopt LIBOR+2% interest, cap guarantee fee 0.5%, limit purchase addition to Rs.7,22,178, remit s.35(2AB) and s.80G &D

Forex derivative losses allowed as bona fide hedging losses; DRP exceeded jurisdiction; TP adjustments limited to LIBOR interest

Transfer pricing margins to be redetermined: include export incentives, cash discounts, miscellaneous expenses, and specific segmental comparables

Reassessment after three years invalid without sanction under Section 151(ii); Principal Commissioner approval insufficient, assessment quashed

Notices issued after 10-year limit under s.149 void for want of jurisdiction; s.150 cannot cure limitation bar

Petitioner must exhaust statutory reply before seeking relief; file substantive response with documents within two weeks

Remand for fresh adjudication after customs house agent given opportunity to submit documentary proof for reimbursable expenses

Revenue's attempt to reopen concluded proceedings over delayed employee contributions rejected; change of law not ground for review

Order excludes specific comparables, deletes TP adjustment for intra-group advertising, and remits s.41(1) and ss.234A/234B issues

Adjustment of s.10(10AA)(ii) exemption without prior intimation under first proviso to s.143(1)(a) invalidates assessment proceedings in law

Management fees to Singapore resident not FTS under Article 12(4) DTAA; s.234A interest waived, s.234B mandatory

Partial disallowance where taxpayer borrowed at 12% and lent at 5%; AO to compute 7% disallowance and reassess under s.234A

Belated Form 10DA filing held procedural; assessee allowed section 80JJAA deduction subject to verification of audit report

Revenue appeals dismissed: nonresident US company's end-user software license fees not 'royalty' under India-US DTAA due to no copyright transfer