S. 92C: Transfer pricing-Arm’s length price-Cannot be treated as a wholesale trader-Tolerance limit of ±3 per cent is applicable.[S. 260A]
S. 92C: Transfer pricing-Arm’s length price-Cannot be treated as a wholesale trader-Tolerance limit of ±3 per cent is applicable.[S. 260A]
S. 92C: Transfer pricing-Arm’s length price-Advance Pricing Agreement (APA)-Cost plus pricing methodology-Advance Pricing Agreement would be persuasive value.[S.92CC]
S. 92C: Transfer pricing-Arm’s length price-Order of the Tribunal deleting the adjustment is affirmed. [S. 260A]
S. 90 : Double taxation relief-elimination of double taxation-Review petition dismissed against order of the Supreme Court that a notification under section 90(1) is a mandatory condition to give effect to a DTAA, or any protocol changing its terms or conditions, which has the effect of altering existing provisions of law-DTAA-India-France-curative petition dismissed. [ITATR. 128, Art. 10, 13]
S. 69A: Unexplained money-Investment at end of year-Deletion of addition by the Tribunal is affirmed by the High Court. [S. 260A]
S. 68: Cash credits-Sale of shares-Short-term capital loss-Order of Tribunal affirmed. [S. 260A]
S. 37(1) : Business expenditure-Company-Advance-Interest-Failure to prove nexus-Order of Tribunal affirming the disallowance is affirmed. [S. 15, 260A]
S. 15: : Salaries-Business income-Director-Professional fees-Failure to furnish documentary evidence-Assessable as income from salary-Order of Tribunal affirmed. [S.17, 28(i), 194J, 260A]
S. 11: Property held for charitable purposes-Failure to file Form No 10 on due date-Delay of 2154 days-Accumulation of income-Delay was condoned-CIT(E) was directed to grant exemption. [S.11(2), 12A, Form No.9A, Form No.10, Art. 226]
S. 11: Property held for charitable purposes-Delay of 447 days while uploading Form No 10B-Oversight on the part of the chartered accountant-Delay was condoned-CIT(E) was directed to grant the relief. [S. 12A, Form No 10B, Art. 226]