Year-end estimated provisions do not trigger TDS until an identifiable payee and crystallised liability exist, defeating default demands.
Struck-off company assessments remain valid for tax liabilities, while unexplained-credit disputes require merits adjudication after a hearing.
Deemed dividend requires a genuine shareholder loan or advance; repayment of a company liability falls outside the provision.
Capital-gains consideration for unquoted share transfers cannot be replaced with a later transaction's value without statutory basis.
Capital-gains bond exemption applies separate financial-year limits when the six-month investment period spans two years.
Scheduled Tribe income exemption requires proof of a bona fide source, excluding unexplained cash deposits.
Tax residency relief for Indian seafarers during COVID-19 was sought through a challenge to administrative guidance.
Section 260A Fact-Finding Limits Bar Reassessment of Book Rejection, Income Estimates, and Fee-Refund Relief on Appeal
Share-capital issue expenses include Registrar fees, allowing preliminary-expenditure amortisation where shares are issued to a holding company.
Decoding seized numerical entries requires reasoned evidentiary support; unsupported multipliers fail, while duplicate taxation and financial incapaci...
Revisionary jurisdiction cannot replace an Assessing Officer's considered view after full disclosure and examination during assessment.
Revision for alleged lack of inquiry fails where assessment records show inquiries, application of mind, and no identified defects.
Interest on excess self-assessment tax refunds runs from payment where appellate relief reduces tax ultimately chargeable.
Advance-tax appeal admission requires examination of claimed absence of taxable income before dismissal or remand
Tax-motivated capital loss remains allowable where share transactions are genuine and lack evidence of an artificial arrangement.
Transfer-pricing rules cannot benchmark independently agreed royalty payments without evidence of an associated-enterprise relationship, requiring del...
Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Cost-to-cost reimbursements exclude value-free third-party expenses from transfer-pricing adjustment, while unsupported salary cross-charges remain ad...
DRP directions bind assessment proceedings, barring protective AMP adjustments and methodology changes through rectification in transfer-pricing asses...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
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