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...
TNMM requires operating profit and operating cost to be computed consistently for the tested party and comparable companies. A provision for doubtful debts linked to sales and trade receivables, and routine business levies such as rates and taxes, may be operating expenses because of their business nexus; income-tax on profits remains excluded. Rule 10B requires FAR-based functional comparability, reliable segmental data and reasonably accurate adjustments for material differences, including scale. A search matrix is evidentiary discipline rather than a statutory bar: an out-of-matrix comparable requires substantiated functional fit and filter compliance, while rejection solely for matrix absence is inappropriate. Contemporaneous documentation must support searches, exclusions, classifications and margin adjustments.
TNMM requires operating profit and operating cost to be computed consistently for the tested party and comparable companies. A provision for doubtful debts linked to sales and trade receivables, and routine business levies such as rates and taxes, may be operating expenses because of their business nexus; income-tax on profits remains excluded. Rule 10B requires FAR-based functional comparability, reliable segmental data and reasonably accurate adjustments for material differences, including scale. A search matrix is evidentiary discipline rather than a statutory bar: an out-of-matrix comparable requires substantiated functional fit and filter compliance, while rejection solely for matrix absence is inappropriate. Contemporaneous documentation must support searches, exclusions, classifications and margin adjustments.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
