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...
Notional interest on interest-free tenancy security deposits is not taxable merely because deposits were received: absent a contractual right to interest or evidence that rent was suppressed or substituted, no real income accrues. Capital introduced by an identified partner through verified bank accounts cannot be added in the firm's hands merely because the partner's antecedent source remains doubtful, unless the funds are shown to belong to the firm. A cash-deposit addition must exclude amounts already treated as partner capital, while unreconciled balances require cash-book verification. Expenditure disallowance under section 14A requires exempt income in the relevant year; ad hoc business-expense disallowance also fails without identified non-business expenditure or record defects.
Notional interest on interest-free tenancy security deposits is not taxable merely because deposits were received: absent a contractual right to interest or evidence that rent was suppressed or substituted, no real income accrues. Capital introduced by an identified partner through verified bank accounts cannot be added in the firm's hands merely because the partner's antecedent source remains doubtful, unless the funds are shown to belong to the firm. A cash-deposit addition must exclude amounts already treated as partner capital, while unreconciled balances require cash-book verification. Expenditure disallowance under section 14A requires exempt income in the relevant year; ad hoc business-expense disallowance also fails without identified non-business expenditure or record defects.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
