Daily Archives: December 1, 2025

I. Transfer Pricing: Netflix India characterized as Limited Risk Distributor; TNMM upheld over TPO’s Royalty Model Issue Characterization: Whether the assessee (Netflix India) should be characterized as a Limited Risk Distributor (LRD) of access to streaming services or as an entrepreneurial service provider owning intangible assets. Methodology: Whether the Transactional Net Margin Method (TNMM) using… Read More »

Addition under Section 69 for cash deposits up to ₹2.5 Lakhs during demonetization deleted per CBDT Instruction 3/2017 Issue Section 69 Addition: Whether the Assessing Officer (AO) was justified in making an addition of ₹2 Lakhs under Section 69 for cash deposits made during the demonetization period, despite CBDT Instruction No. 3/2017 which directed no… Read More »

Detailed documentation of share transactions defeats “Penny Stock” addition under Section 68 Issue Whether the Assessing Officer (AO) is justified in treating the sale proceeds of shares as “unexplained cash credit” under Section 68 solely on the suspicion of them being “penny stocks,” when the assessee has provided complete documentary evidence substantiating the genuineness of… Read More »

Section 10AA deduction allowed on voluntary TP adjustment under APA; Ad-hoc Section 14A disallowance deleted Case I: Transfer Pricing & Section 10AA   Issue Whether a taxpayer is entitled to claim a deduction under Section 10AA (for SEZ units) on the additional income voluntarily offered as a Transfer Pricing (TP) adjustment pursuant to an Advance… Read More »

TPO must adhere to own turnover filters; PF delay due to banking glitch distinguishable from Checkmate ruling Case I: Transfer Pricing – Consistency in Filters   Issue Whether the Transfer Pricing Officer (TPO) is justified in including a comparable company that fails the specific turnover filter applied by the TPO himself during the benchmarking process… Read More »

ITR REFUND PROCESSING , SUNDAY की SPEED ! ITR NOT PROCESSED , INCOME TAX REFUND NOT RECEIVED