Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
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 ...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
