Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
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...
Cash returned by builders from property payments made through banking channels constitutes circulation of explained funds, not unexplained money, unless evidence establishes a separate unexplained asset or accretion; the related addition was deleted. Alleged cash interest from builder financing was unsustainable where disclosed property investments, rent and capital gains supported appreciation rather than separate interest; that addition was deleted. Acquisition below stamp-duty value can attract section 56(2)(x)(b) irrespective of a transaction's builder-financing character, but disputed values require fair-market-value determination before taxability is decided; the issue was remanded. Set-off of brought-forward long-term capital loss was also remanded for verification of eligibility and the character of current-year capital gains.
Cash returned by builders from property payments made through banking channels constitutes circulation of explained funds, not unexplained money, unless evidence establishes a separate unexplained asset or accretion; the related addition was deleted. Alleged cash interest from builder financing was unsustainable where disclosed property investments, rent and capital gains supported appreciation rather than separate interest; that addition was deleted. Acquisition below stamp-duty value can attract section 56(2)(x)(b) irrespective of a transaction's builder-financing character, but disputed values require fair-market-value determination before taxability is decided; the issue was remanded. Set-off of brought-forward long-term capital loss was also remanded for verification of eligibility and the character of current-year capital gains.
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TaxTMI 
TaxTMI 
of 4902 
