Income Tax – Transfer pricing, Exclusion of comparables, Functional dissimilarity – The Tribunal directed the Transfer Pricing Officer to exclude three companies as comparables on the ground that they were functionally dissimilar to the Respondent, and the Revenue challenged the exclusion before the...
Income Tax – Retrospective applicability of Rule 8D to Assessment Year 2003-04 – Appellant is a Government Company engaged in the business of financial and industrial undertaking. The AO made disallowance of interest and administrative expenses in respect of exempt income while applying Rule 8D of t...
Income Tax – Validity of adjustment in respect of specified domestic transaction under clause (i) of Section 92BA omitted by Finance Act, 2017, Allowability of mark-to-market loss on equity and currency futures, Disallowance under Section 14A read with Rule 8D - Respondent is an NBFC which paid rati...
Income Tax - Limitation for passing final assessment order under Section 144C(13) of the Income Tax Act, 1961 - Appellant’s case was selected for scrutiny and reference was made to the Transfer Pricing Officer, who made an upward adjustment in respect of the international transaction of intra-group...
Income Tax – Revision of assessment accepting write-off of insurance receivable, Lack of enquiry versus inadequate enquiry, Possible view, Explanation 2 to Section 263, Revision triggered by audit objection, Prejudice to the interests of the Revenue, Write-off of insurance receivable on final reject...