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I-T - Decision to restore matter to AO shall in no way be construed as reflection or expression on merits of dispute: ITAT...
DTAA - Amount received for fabrication/refurbishing services (bushings) provided by foreign AE to Indian arm, is not fees for technical service, ...
I-T - Order of interim stay stays operative part of decision but does not wipe out its ratio decidendi or nullify precedent unless explicitly set...
I-T - Final assessment in name of non-existent entity, i.e., amalgamating company that had ceased to exist pursuant to NCLT-approved scheme of am...
TP - Outer time limit of 33 months in case of reference to TPO u/s 153 would not refer to draft order, but only to final order: ITAT ...
I-T - Non-obstante clause would not exclude operation of Section 153 as a whole: ITAT ...
I-T - Approval obtained u/s 151(i) of new regime instead of authority specified u/s 151(ii) of new regime, vitiates jurisdiction of AO to issue n...
I-T - Payment for voice termination services is not taxable as royalty, if there is no transfer of intellectual property rights, no use or right ...
INTL - Sections 144C and 153 are interdependent & overall time limit prescribed u/s 153 applies to entire assessment proceedings, including DRP d...
TP - Transfer pricing adjustment on account of ESOP/RSU is unsustainable as it was based on a notional & hypothetical cost not incurred by assess...
I-T - If pursuant to court-approved amalgamation, cost of investment in shares of amalgamating company exceeds value of net assets taken over, su...
TP - AMP expenditure incurred by the assessee, which is the Indian arm of a foreign company, would not constitute international transactions: ITA...
TP - When computing notional interest on delayed realization of trade receivables arising from international transactions denominated in foreign ...
TP - Outer time limit of 33 months in case of reference to TPO u/s 153 would not refer to draft order, but only to final order: ITAT ...
INTL - Assessment order erroneous where it allows deduction of belated deposit of employee's contribution to PF & ESI, given the same is expressl...
INTL - For purpose of section 263, correctness of assessment order has to be examined w.r.t. the record as it exists at time of revision: ITAT ...
I-T - Time limits prescribed u/s 153 are applicable to assessments conducted under DRP route specified in section 144C: ITAT...
I-T - Making an unsustainable claim does not per se amount to furnishing inaccurate particulars, so as to warrant imposing penalty u/s 271(1)(c) ...
I-T - Time limit prescribed u/s 153 has to be adhered to and that both Section 144C and 153 are mutually inclusive and interdependent: ITAT...
I-T - AO's failure to test computation under Rule 8D demonstrates case of lack of inquiry, making deeming provisions of Explanation 2, clause (a)...
 
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