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    Index-based derivatives are not shares under the India-Mauritius DTAA, so gains fall under the residuary residence-based article.
    Transfer pricing adjustments: pass-through costs, working capital relief, DRP binding directions, and foreign tax credit verification.
    Mechanical approval under section 153D invalidates search assessments where the approving authority fails to apply independent mind.
    Section 153C jurisdiction fails where third-party loose papers and digital traces do not establish a credible nexus with the assessee.
    Depreciation on land conversion charges denied, but penalty deleted because the underlying tax claim was fully disclosed and debatable.
    RERA compensation for extinguishment of property rights treated as long-term capital gains, not income from other sources.
    Charitable trust registration cannot be denied solely for limited initial activity where the objects and deed show public charitable purpose.
    APA-based transfer pricing, MAT book profit review, and consequential interest recomputation were sent back for fresh consideration.
    Project completion method: promotional expenses stay revenue, while direct project costs must be capitalised in work-in-progress.
    Transfer pricing comparables excluded for turnover and functional mismatch; foreign currency receivables benchmarked to LIBOR plus spread.
    Aggregated TNMM applies to management charges, while delayed receivables interest must be recomputed using average LIBOR.
    Condonation of delay in Form 10 allowed where refusal would cause grave hardship and no benefit arose from the delay.
    Charitable trust registration cancellation survives where notice was specific, but it operates prospectively only from cancellation.
    Trade advances in regular business dealings fall outside deemed dividend treatment under section 2(22)(e).
    Section 87A rebate confined to normal-rate income; special-rate capital gains tax excluded in mixed-income cases.
    Integrated business model accepted for transfer pricing, with entity-level TNMM applied instead of separate segment benchmarking.
    Notional valuation cannot justify export sales addition when declared exports are genuine and no extra consideration is proved.
    CSR donations can still qualify for section 80G relief; receivables adjustment and other issues were remanded.
    Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
    TNMM accepted for intra-group services and SAP costs, while provident fund disallowance under employee contribution was sustained.
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Acts Income Tax