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 ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
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Transfer-pricing comparability under the transactional net margin method requires economically reliable uncontrolled benchmarks under Section 92C and Rule 10B. Turnover is not a standalone statutory bar, but material scale differences may justify excluding enterprises where brand value, intangibles, bargaining power, assets, risks or market conditions could affect margins. A turnover threshold must therefore be supported by transaction-specific comparability analysis rather than applied as a universal rule. Related-party transaction filters seek to reduce the influence of controlled dealings on comparable profitability. A 15% threshold is ordinarily appropriate where sufficient reliable comparables exist; a higher threshold requires a recorded finding that lower-RPT comparables are unavailable. Functional, asset and risk analysis remains essential, and appellate review may address disregard of statutory criteria or perverse findings.
Transfer-pricing comparability under the transactional net margin method requires economically reliable uncontrolled benchmarks under Section 92C and Rule 10B. Turnover is not a standalone statutory bar, but material scale differences may justify excluding enterprises where brand value, intangibles, bargaining power, assets, risks or market conditions could affect margins. A turnover threshold must therefore be supported by transaction-specific comparability analysis rather than applied as a universal rule. Related-party transaction filters seek to reduce the influence of controlled dealings on comparable profitability. A 15% threshold is ordinarily appropriate where sufficient reliable comparables exist; a higher threshold requires a recorded finding that lower-RPT comparables are unavailable. Functional, asset and risk analysis remains essential, and appellate review may address disregard of statutory criteria or perverse findings.
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