Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
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.
TaxTMI 
TaxTMI 
of 4910 
