Valuation Officer estimates govern property-value additions once statutory valuation is invoked, requiring fresh consideration of objections and compa...
Waiver of written show-cause notice may prevent a later procedural challenge after participation in customs adjudication, preserving statutory appella...
Retrospective invalidity of ocean-freight IGST supports refunds despite non-party status and prior credit utilisation, subject to authorised appeal gr...
Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
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Transfer-pricing benchmarking under TNMM required royalty for engine technology to remain aggregated with the manufacturing segment once TNMM had been accepted as the most appropriate method; separate royalty benchmarking was deleted for both assessment years. Engineering and design comparability required exclusion of a company with diversified services, no reliable segmental data, a different functional profile and an extraordinary acquisition; margins require recomputation. The expenditure disallowance relating to exempt dividend income was sustained under section 14A read with Rule 8D. Tax liability, credits and interest computations were remitted for verification and correction.
Transfer-pricing benchmarking under TNMM required royalty for engine technology to remain aggregated with the manufacturing segment once TNMM had been accepted as the most appropriate method; separate royalty benchmarking was deleted for both assessment years. Engineering and design comparability required exclusion of a company with diversified services, no reliable segmental data, a different functional profile and an extraordinary acquisition; margins require recomputation. The expenditure disallowance relating to exempt dividend income was sustained under section 14A read with Rule 8D. Tax liability, credits and interest computations were remitted for verification and correction.
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