Section 153C requires person-specific search authority and year-specific incriminating material for unabated assessments while preventing unsupported ...
Equivalent-value attachment can reach pre-existing assets, but jointly owned property remains protected beyond the accused's attributable proceeds of ...
TNMM benchmarking required exclusion of functionally dissimilar, diversified, and unsegmented companies from the comparable set for manufacturing and engineering-estimation segments. Intra-group support-service charges required fresh verification of evidence showing benefits received and benchmarking under TNMM; the issue was remanded. Business-connected reversals, miscellaneous income, foreign-exchange gains and export incentives were treated as operating income where related expenditure had been treated as operating, increasing the profit level indicator. In the extraordinary COVID-affected year, current-year margins of final comparables were required for comparison rather than weighted averages including normal years. Interest on overdue associated-enterprise receivables was not imputable where audited accounts showed the taxpayer was debt-free and lease liabilities were not borrowings.
TNMM benchmarking required exclusion of functionally dissimilar, diversified, and unsegmented companies from the comparable set for manufacturing and engineering-estimation segments. Intra-group support-service charges required fresh verification of evidence showing benefits received and benchmarking under TNMM; the issue was remanded. Business-connected reversals, miscellaneous income, foreign-exchange gains and export incentives were treated as operating income where related expenditure had been treated as operating, increasing the profit level indicator. In the extraordinary COVID-affected year, current-year margins of final comparables were required for comparison rather than weighted averages including normal years. Interest on overdue associated-enterprise receivables was not imputable where audited accounts showed the taxpayer was debt-free and lease liabilities were not borrowings.
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