Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Third-party seized diaries and excel sheets cannot support additions for alleged cash rebate repayment or unaccounted molasses sales unless they clearly establish the transactions and are supported by independent corroborative evidence. Unsigned, ambiguous entries, a retracted statement, and denial of cross-examination undermine their evidentiary value and breach natural justice; the related additions were deleted. Disallowance computed under section 14A read with Rule 8D cannot be imported into book-profit computation under section 115JB, requiring deletion of that adjustment. Components integral to a cogeneration plant, without standalone function, qualify for the higher depreciation rate applicable to the plant; the depreciation disallowance was deleted.
Third-party seized diaries and excel sheets cannot support additions for alleged cash rebate repayment or unaccounted molasses sales unless they clearly establish the transactions and are supported by independent corroborative evidence. Unsigned, ambiguous entries, a retracted statement, and denial of cross-examination undermine their evidentiary value and breach natural justice; the related additions were deleted. Disallowance computed under section 14A read with Rule 8D cannot be imported into book-profit computation under section 115JB, requiring deletion of that adjustment. Components integral to a cogeneration plant, without standalone function, qualify for the higher depreciation rate applicable to the plant; the depreciation disallowance was deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
