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 ...
Partial appellate remand of transfer-pricing comparability issues, without setting aside or cancelling the assessment, requires effect to be given otherwise than through a fresh assessment. Where the remand requires fresh examination and hearing, the limitation period applicable to consequential action applies. A Tribunal remand to the Transfer Pricing Officer does not constitute an Assessing Officer's reference to that officer and therefore does not trigger the additional limitation extension available for such a reference. The consequential assessment, completed after the prescribed deadline, was quashed as time-barred; the remaining transfer-pricing challenges became infructuous.
Partial appellate remand of transfer-pricing comparability issues, without setting aside or cancelling the assessment, requires effect to be given otherwise than through a fresh assessment. Where the remand requires fresh examination and hearing, the limitation period applicable to consequential action applies. A Tribunal remand to the Transfer Pricing Officer does not constitute an Assessing Officer's reference to that officer and therefore does not trigger the additional limitation extension available for such a reference. The consequential assessment, completed after the prescribed deadline, was quashed as time-barred; the remaining transfer-pricing challenges became infructuous.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
