Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Cross-segment derivatives manipulation: integrated order patterns can support interim restraints, while director liability requires responsibility, co...
Reassessment founded on an audit objection requires the Assessing Officer to verify the record and independently apply mind. An allegation that health and education cess had been deducted could not support reassessment where no such deduction was claimed and the audit premise was unverified. Interest on borrowed funds invested in a subsidiary must be assessed through commercial expediency from a prudent businessperson's standpoint; reassessment could not proceed where that governing principle was not distinguished on recorded facts. The reassessment notices and order were quashed.
Reassessment founded on an audit objection requires the Assessing Officer to verify the record and independently apply mind. An allegation that health and education cess had been deducted could not support reassessment where no such deduction was claimed and the audit premise was unverified. Interest on borrowed funds invested in a subsidiary must be assessed through commercial expediency from a prudent businessperson's standpoint; reassessment could not proceed where that governing principle was not distinguished on recorded facts. The reassessment notices and order were quashed.
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