Daily Archives: August 21, 2026

Reassessment based on previously examined bank records without new tangible material constitutes impermissible change of opinion.

By | August 21, 2026
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Reassessment based on previously examined bank records without new tangible material constitutes impermissible change of opinion. Issue Whether an assessment completed under Section 143(3) can be reopened under Section 147 to examine bank credits and gross receipts that were already scrutinized, in the absence of any new tangible material. Facts Assessee’s return for AY 2012-13… Read More »

Transfer pricing benchmarking requires strict functional, product, and asset comparability while honoring binding administrative directives.

By | August 21, 2026
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Transfer pricing benchmarking requires strict functional, product, and asset comparability while honoring binding administrative directives. Issue Whether transfer pricing adjustments, selection/exclusion of comparable entities, computation of operating margins, allocation of working capital, choice of benchmarking methods (TNMM vs. CUP vs. Berry Ratio), and disallowance of expatriate salaries can be sustained when facing functional dissimilarities, non-binding… Read More »

Estimation of gross profit within industry range and disallowance of reasonable interest on unsecured loans are unsustainable without identifying specific defects in audited accounts.

By | August 21, 2026
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Estimation of gross profit within industry range and disallowance of reasonable interest on unsecured loans are unsustainable without identifying specific defects in audited accounts. Estimation of gross profit within industry range and disallowance of reasonable interest on unsecured loans are unsustainable without identifying specific defects in audited accounts. Issue Whether the Assessing Officer can reject… Read More »

Contributions to Leave Encashment Fund, pre-AY 2015-16 CSR expenses, and disputed accrued rentals are allowable business deductions for Major Port Authority.

By | August 21, 2026
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Contributions to Leave Encashment Fund, pre-AY 2015-16 CSR expenses, and disputed accrued rentals are allowable business deductions for Major Port Authority. Issue Whether contributions to an insurer-managed leave encashment fund, pre-AY 2015-16 CSR expenses under binding guidelines, staff welfare payments misclassified as donations, disputed unrecovered estate rentals, and higher depreciation on port structures are allowable… Read More »