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...
Tax deduction at source on interest arises on credit or payment, whichever occurs first; a brought-forward interest liability does not itself constitute a current-year credit. The real income doctrine requires objectively established contemporaneous circumstances showing that income did not accrue, rather than merely an absence of accounting entries. Unexplained-expenditure provisions apply to expenditure incurred in the relevant financial year and do not extend to an earlier capital advance merely carried forward, particularly where recorded in regular books. A capital work-in-progress write-off already added back in computing business income should not be added again, as this would result in double taxation. Interest capitalised to work-in-progress is not subject to disallowance where tax was deducted and deposited within the prescribed return-filing timeline.
Tax deduction at source on interest arises on credit or payment, whichever occurs first; a brought-forward interest liability does not itself constitute a current-year credit. The real income doctrine requires objectively established contemporaneous circumstances showing that income did not accrue, rather than merely an absence of accounting entries. Unexplained-expenditure provisions apply to expenditure incurred in the relevant financial year and do not extend to an earlier capital advance merely carried forward, particularly where recorded in regular books. A capital work-in-progress write-off already added back in computing business income should not be added again, as this would result in double taxation. Interest capitalised to work-in-progress is not subject to disallowance where tax was deducted and deposited within the prescribed return-filing timeline.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
