Unauthorised supervisory approval vitiates a survey-based assessment by undermining the Assessing Officer's independent quasi-judicial discretion.
Depreciation option claims with full disclosure and bona fide revision do not establish inaccurate income particulars for penalty.
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Asset-based escaped-income satisfaction is mandatory for extended Section 153C jurisdiction; a cash-transaction note alone invalidates the assessment.
Arm's length pricing for corporate guarantees and foreign-currency receivables applies a reduced commission, LIBOR benchmark, and credit period.
Agricultural land character at transfer determines capital-gains treatment despite purchaser obtaining later non-agricultural-use permission.
Accommodation-entry interest is disallowed, but tax withholding is excluded and unsupported estimated commission additions fail.
Transitional reassessment limitation preserves the old regime's time bar, invalidating notices issued after the applicable period expired.
Deemed annual value of completed unsold developer units must use municipal rateable value, subject to verified purchaser-advance exclusions.
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Inherent quashing jurisdiction cannot decide disputed defences on non-supply of seized material or wilful failure to file returns.
Eligible industrial deductions and book-profit adjustments turn on income nexus, exempt-fund presumption, valuation, and lawful appellate claims.
Website development depreciation, banking gateway fees, and revenue advertising expenses receive favourable treatment under discussed tax principles.
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...
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TaxTMI 
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