Charitable sports promotion: sponsorship receipts alone did not defeat registration where funds supported tournaments and player development activitie...
Overdue associated-enterprise receivables: debt-free status defeated notional-interest adjustment, while employee stock-option costs qualified as busi...
Retrospective assessment-limitation amendments validate final orders while contemporaneous segment data governs transfer-pricing comparability and tol...
Transfer pricing adjustments must track international transactions, while unsupported AMP adjustments and unsuitable manufacturing comparables require...
Transfer-pricing adjustments must reflect functional comparability, working-capital effects, and avoid duplicating interest on associated-enterprise r...
Section 153C proceedings against a person other than the searched person require a satisfaction note as a precondition. Where the searched person's assessment has concluded, the satisfaction note must be recorded immediately thereafter; a delay exceeding four years does not meet that requirement. Proceedings initiated for Assessment Year 2017-18 on the basis of such delayed recording were invalidated, and the related notice, consequential order and demand notice were quashed.
Section 153C proceedings against a person other than the searched person require a satisfaction note as a precondition. Where the searched person's assessment has concluded, the satisfaction note must be recorded immediately thereafter; a delay exceeding four years does not meet that requirement. Proceedings initiated for Assessment Year 2017-18 on the basis of such delayed recording were invalidated, and the related notice, consequential order and demand notice were quashed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
