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I-T - Receipts from sale of Renewable Energy Certificates are capital receipts and are not taxable as revenue income: ITAT ...
TP - Section 94B applies only when debt is from non-resident AE and no corresponding restriction exists for resident AE borrowings: ITAT...
TP - Functional dissimilarity, turnover filter, and abnormal profit calls for exclusion of comparable: ITAT...
TP - TPO cannot question commercial expediency once expenditure is shown to have been incurred for business purposes; assessee must nevertheless ...
TP - Comparables selected in previous assessment years need to be included in current year as well, in identical facts & circumstances: ITAT...
TP - Adjustment on account of interest paid on NCDs cannot be made by ignoring internal CUP: ITAT...
TP - Amortization of goodwill is an extraordinary item affecting normal profitability & should be treated as non-operating for purpose of computi...
TP - Outer time limit u/s 153 applies to final assessment order including transfer pricing determination and not merely to draft order: ITAT ...
TP - No ALP is to be made on outstanding receivables in absence of any inter-company agreement or email correspondence between AES: ITAT ...
I-T - Mere grant of stay or pendency of further proceedings does not obliterate existence or binding nature of judgment unless it is set aside: I...
TP - Functional dissimilarity and variation in business segment calls for exclusion of comparable: ITAT ...
TP - DRP process forms part of assessment proceedings and does not displace outer limitation prescribed by section 153: ITAT ...
I-T - Buy-back amounted to transfer of shares within same corporate group and qualified as corporate reorganization under Article 13(5) of Indo N...
TP – If comparable is already accepted by TPO and such acceptance is upheld by CIT (A), then Revenue cannot seek its exclusion on ground that i...
I-T – If borrowed funds are used for expansion or extension of business, including through acquisition of entity in same line of business, inte...
I-T - Sections 144C and 153 are mutually inclusive and period of limitation for passing final assessment order u/s 144C(13) has to be determined ...
DTAA - Benefit of FTC u/s 90 r/w applicable DTAA cannot be denied merely on account of delay in filing Form 67 when taxes have actually been paid...
I-T - Sections 144C & 153 are inter-dependent; overall time limit prescribed u/s 153 applies to completion of entire assessment, including DRP pr...
I-T - Time-limit prescribed u/s 153 has to be adhered to and both Section 144C and 153 are mutually inclusive & interdependent: ITAT ...
I-T - If notice issued by AO u/s 148 is barred by limitation as per mandate of ‘first proviso' to Sec 149, consequential assessment order passe...
 
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