Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Transfer-pricing benchmarking confines adjustments to associated-enterprise transactions and integrates delayed receivables through TNMM working-capit...
Medical relief status protects government-contracted mobile healthcare from commercial classification, while provisional registration cancellation req...
Charitable registration cancellation requires proof that educational activities abandoned their objects; incidental receipts and retained surplus are ...
Prospective customs notification amendments cannot bar provisional release consideration for earlier imports when bills of lading predate their commen...
Personal guarantor insolvency jurisdiction follows the corporate debtor's CIRP Bench, enabling inter-territorial transfer and preventing parallel proc...
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Return-processing adjustments to a charitable accumulation claim require compliance with the first proviso to section 143(1A), including an opportunity before the adjustment is made. Non-compliance vitiated the adjustment. Where an assessee's accumulated amount was incorrectly reported through an inadvertent return-form error, supported by an indemnity bond and a revised Form 10B, rectification required substantive consideration rather than rejection solely on a technical basis. The processing and rectification orders were set aside and remanded for consideration of the revised audit report, determination of correct income, and grant of admissible relief.
Return-processing adjustments to a charitable accumulation claim require compliance with the first proviso to section 143(1A), including an opportunity before the adjustment is made. Non-compliance vitiated the adjustment. Where an assessee's accumulated amount was incorrectly reported through an inadvertent return-form error, supported by an indemnity bond and a revised Form 10B, rectification required substantive consideration rather than rejection solely on a technical basis. The processing and rectification orders were set aside and remanded for consideration of the revised audit report, determination of correct income, and grant of admissible relief.
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