Road restoration charges constitute taxable services when requested for commercial pipeline activity, requiring reverse-charge GST from the business r...
Interest on delayed release of requisitioned cash includes statutory pre-assessment interest and restitutionary compensation for unlawful post-assessm...
Incomplete inventory records justify rejecting accounts, while profit estimation requires relevant comparable material and interest falls under other ...
Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
PBDIT was treated as the appropriate profit level indicator for manufacturing transactions where materially higher fixed assets and depreciation distorted comparability under the operating-profit-to-operating-cost indicator and no reliable depreciation adjustment to comparables was feasible. The taxpayer's and comparables' margins were therefore to be recomputed on a PBDIT basis. A working-capital adjustment was required in benchmarking the international transactions. Set-off of brought-forward business losses and unabsorbed depreciation was mandatory under the Act, subject to verification of the losses available, because the final assessment did not consider or give reasons for denying the claim.
PBDIT was treated as the appropriate profit level indicator for manufacturing transactions where materially higher fixed assets and depreciation distorted comparability under the operating-profit-to-operating-cost indicator and no reliable depreciation adjustment to comparables was feasible. The taxpayer's and comparables' margins were therefore to be recomputed on a PBDIT basis. A working-capital adjustment was required in benchmarking the international transactions. Set-off of brought-forward business losses and unabsorbed depreciation was mandatory under the Act, subject to verification of the losses available, because the final assessment did not consider or give reasons for denying the claim.
Note: It is a system-generated summary and is for quick reference only.