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    Joint transferee TDS threshold under immovable property purchases must be tested on each purchaser's share, not the total deed value.
    Transfer pricing operating margin: SEIS reversal, foreign exchange gains and working capital adjustment shape TNMM comparability
    Transfer pricing comparability under TNMM refined: functional filters, aggregate RPT testing, and working capital adjustments controlled the outcome.
    TNMM and transfer pricing adjustments: receivables deleted, ECB interest upheld, leasehold amortisation allowed, royalty remanded
    Transfer pricing under External TNMM prevails where internal comparables and segment re-casting lack factual support.
    Transfer pricing on overdue receivables and CSR-linked 80G deduction were reshaped by the Tribunal's recomputation directions.
    Jurisdiction and regular assessment are prerequisites for prosecution over failure to file an income tax return.
    Reassessment limitation and sanction rules under the amended regime were upheld for the relevant assessment year.
    Third-party seized material needs independent corroboration before alleging cash receipts, profit estimation, or on-money payments.
    Appellate jurisdiction is confined to the year under appeal; directions to reopen earlier years were expunged.
    Rejection of books and profit estimation: ITAT upheld section 145(3) but cut estimated profit from 8% to 5%.
    Penalty for inaccurate particulars fails where full disclosure is made and the claim is only legally unsustainable.
    Transfer pricing on rupee-denominated debentures: ITAT upheld 10% arm's length interest and corrected the adjustment amount.
    Service PE under India-US DTAA turns on unique solar days, not overlapping man-days, so the 90-day threshold was not crossed.
    IDS-2016 declaration taxed in wrong year; Tribunal deleted reassessment for AY 2013-14 after non-payment within time.
    Invalid reassessment sanction beyond three years vitiates notice and assessment where approval is taken from the wrong authority.
    Invalid reassessment sanction and unsupported cash-addition claims fail; DCF share valuation upheld, with only profit element taxed on cash sales.
    Revenue expenditure, proportionate TDS credit and real income principles sustained against tax additions on appeal.
    Prospective cancellation for specified violation under charitable registration law fails where alleged breaches predate the regime
    Section 68 additions fail without assessee-specific evidence; declared trading income and proved loan documents defeat the Revenue's case.
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Acts Income Tax