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    Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
    Transfer pricing comparability: exclusion of one comparable upheld, another included, and working capital adjustment directed.
    Service of assessment order is essential before tax recovery or interest can be enforced against an assessee.
    Rule 46A compliance requires a speaking order and opportunity to rebut before additional evidence is used in appeal.
    Share valuation under section 56(2)(viib) must be done afresh for each issue of unquoted equity shares, the ITAT held.
    Section 10AA, bad debts and section 41(1) rulings turn on export proof, write-off evidence and capital liability adjustment.
    Common area maintenance recoveries justify business expenditure allowance and limit apportionment against rental income claims.
    DCF share valuation cannot be replaced without defect; protective addition fails when taxability uncertainty is absent.
    Place of effective management must rest on proved facts, not institutional deference; global income addition deleted.
    Permanent establishment through branch office continuity led to remand for fresh profit attribution and taxability review.
    Section 87A rebate applies under the new tax regime even where tax arises on short-term capital gains under section 111A.
    Protective assessment and TDS credit issues remanded for fresh verification of ownership, exemption eligibility, and income nexus.
    Arm's length remuneration for a dependent agent PE bars further profit attribution under Rule 10.
    Section 80-IA(10) requires proof of arrangement and ordinary-profit benchmark; sister concern margin could not cut Section 10B deduction.
    Natural justice and remand compliance: show-cause notices in penalty proceedings quashed for missed deadline
    Live nexus required for reassessment based on seized material; broker's register entry could not justify reopening.
    Unaccounted production addition failed where the comparison used unlike units and lacked corroborative search material.
    Search assessment limitation requires inclusion of the search year in the ten-year block; notice for an earlier year was quashed.
    Merits-based appellate adjudication required; Tribunal cannot dismiss an appeal by relying on delay alone.
    Ad hoc gross profit estimation rejected where surrendered excess stock had to be accounted for under AS-2 valuation principles.
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Acts Income Tax