Foreign-currency loan benchmarking follows the loan currency, while export hedging losses qualify as non-speculative business losses.
Delayed initiation of TDS return penalties after nine years rendered the penalty illegal and unsustainable.
Project-development assistance treated as capital, while infrastructure construction costs may be amortised over the concession period.
Delayed trade receivables require separate transfer pricing benchmarking, subject to debt-free status and an appropriate credit period.
Modified returns, MAT book profit limits, and tested-party selection shape transfer pricing treatment of integrated intra-group services.
Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Share valuation method choice protects DCF valuations from replacement with NAV, though projections remain open to scrutiny.
Penalty immunity requires reconsideration where rectification removes the assessment demand and leaves a refund instead.
Under-reporting penalty applies when taxable income is not returned, even if reassessment disclosure is accepted without additions.
Co-operative investment income and balance additional depreciation claims succeeded, with milk cans recognised as eligible plant and machinery.
Bogus purchase disallowance limited to embedded profit where sales and books remain accepted; reassessment procedure upheld.
Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Sole testamentary trusts fall outside maximum marginal rate taxation despite assessment as an association of persons.
TDS on agricultural land transfers cannot arise through enhanced PAN-based rates where the primary deduction provision is inapplicable.
Diamond grading reports do not make available technical know-how, so non-resident certification payments may fall outside withholding tax.
Goodwill from slump sales remains depreciable where newly created, while non-compete fees cannot support depreciation claims.
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Documented funding sources and pending valuation reference defeat unexplained investment and stamp-duty differential additions for property purchases.
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
TaxTMI 
TaxTMI 
of 1978 
