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 ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Residual Profit Split Method, once accepted and computed for an integrated IT-enabled and data analytics services transaction, cannot be supplemented by a further entity-level margin comparison using another transfer-pricing method. A different prescribed method may be used only after RPSM is rejected for cogent reasons; the entity-level adjustment was therefore deleted. Corporate guarantee pricing cannot mechanically adopt commercial bank-guarantee rates. The interest-saving approach requires transaction-specific analysis of the associated enterprise's credit profile, borrowing terms, currency, tenure, security and guarantee coverage; the guarantee commission was remanded for fresh determination. Current-year business-loss set-off requires verification against return, computation and assessment records.
Residual Profit Split Method, once accepted and computed for an integrated IT-enabled and data analytics services transaction, cannot be supplemented by a further entity-level margin comparison using another transfer-pricing method. A different prescribed method may be used only after RPSM is rejected for cogent reasons; the entity-level adjustment was therefore deleted. Corporate guarantee pricing cannot mechanically adopt commercial bank-guarantee rates. The interest-saving approach requires transaction-specific analysis of the associated enterprise's credit profile, borrowing terms, currency, tenure, security and guarantee coverage; the guarantee commission was remanded for fresh determination. Current-year business-loss set-off requires verification against return, computation and assessment records.
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