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    Consequential assessment under revision loses force when section 263 orders are remanded; appeal becomes infructuous.
    Make available test bars tax on management and business support fees under India-Singapore treaty, deleting the addition
    Telecom transfer pricing disputes favour uncontrolled comparables, contemporaneous ECB benchmarks and deductibility of operating charges.
    Turnover filter, functional comparability and subvention receipts shaped transfer pricing benchmarking for the distribution segment.
    Business expenditure disallowance on suspicion rejected where no finding of non-genuineness was recorded in assessment
    Diversion of income by overriding title defeats taxability of interest credited to development funds and allows promotional expenditure.
    Deemed application under section 11 recognised despite no Form 9A, where written option and disclosure were timely.
    Books rejection and reassessment additions fail without cogent evidence, while donation disallowance needs fresh hearing and cross-examination.
    Transfer pricing adjustments under TNMM were curtailed where Safe Harbour rules and nil ALP were wrongly applied.
    Presumption of culpable mental state upheld where false refund claim based on fabricated housing-loan documents was proved
    Former director not liable for non-filing prosecution where resignation predated the company's default period
    IBC liquidation can render income-tax appeals infructuous when pre-transfer liabilities are confined to the liquidation process.
    Domestic application of income: scholarships paid in India for overseas study do not trigger denial of charitable registration.
    Section 10(26) exemption for salary income requires proof of territorial nexus; work-from-home claim sent back for reconsideration.
    Mandatory notice in reassessment and proper draft assessment procedure under section 144C are jurisdictional requirements
    Treaty rate limits dividend distribution tax on Swiss shareholder dividends; excess tax refund directed under applicable treaty
    MAT exclusion for SEZ income, section 14A cap and strict proof of SEZ deductions shaped liability outcomes.
    Consequential depreciation on non-compete fee upheld; TV serial production costs allowed, subscription revenue remanded for factual verification.
    Fresh allotment breaks link with earlier valuation date; disputed stamp duty value sent back for DVO review
    Royalty versus copyrighted article: software subscriptions were not taxable, while customer-specific professional services were treated as FTS/FIS.
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Acts Income Tax