Daily Archives: August 29, 2026

TP Adjustments on Aggregated Royalty, Intra-Group Services, and Receivables Deleted while Working Capital Adjustment Remanded

By | August 29, 2026
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TP Adjustments on Aggregated Royalty, Intra-Group Services, and Receivables Deleted while Working Capital Adjustment Remanded Issue Whether transfer pricing adjustments concerning operating cost items, turnover filters, comparable selections across segments, notional interest on delayed receivables, aggregated royalty payments, intra-group service charges, working capital adjustments, and non-TDS disallowances under section 40(a)(ia) are legally sustainable for AY… Read More »

DDT on Dividends to Non-Residents Restricted to DTAA Rates; Corporate Club Membership Fees Fully Allowable

By | August 29, 2026
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DDT on Dividends to Non-Residents Restricted to DTAA Rates; Corporate Club Membership Fees Fully Allowable Issue Whether Dividend Distribution Tax (DDT) under section 115-O on dividends paid to non-resident shareholders is capped by DTAA rates, and whether corporate club membership fees qualify as allowable business expenditure under section 37(1). Facts DDT on Foreign Shareholders (AYs… Read More »

Ad hoc Disallowances, Form 26AS Additions, and Cessation Triggers Deleted; Flood Relief Expenses Remanded for Assessment

By | August 29, 2026
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Ad hoc Disallowances, Form 26AS Additions, and Cessation Triggers Deleted; Flood Relief Expenses Remanded for Assessment Issue Whether ad hoc expense disallowances, section 40(a)(ia) penalties for non-compliance with section 194C(7), section 41(1) additions on outstanding trade advances, section 26AS interest adjustments without accrual, high repair expenses on leased property, infrastructure sharing payments, and section 43B… Read More »

Bad Debt Claims, MAT Credit Corrections, and Rectification Orders Remanded for Verification and Natural Justice

By | August 29, 2026
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Bad Debt Claims, MAT Credit Corrections, and Rectification Orders Remanded for Verification and Natural Justice Issue Whether the write-off of advances, correction of MAT credit without a revised return, and ex-parte rectification orders adding FTS disallowances require factual verification and adherence to natural justice. Facts Bad Debts/Advances Write-off: For AY 2011-12, the assessee (an automotive… Read More »

By | August 29, 2026
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Interest Disallowance Remanded for Verification While Section 40(a)(ia) and Land Conversion Charge Disallowances are Upheld Issue Whether interest on borrowed capital for work-in-progress requires verification, whether section 40(a)(ia) applies to paid amounts, and whether land conversion charges/interest qualify for business expenditure or capital allowances. Facts Interest on Borrowed Capital: For AYs 2009-10 to 2010-11, the… Read More »

TP Adjustments, 80-IA Deductions, and Section 14A Disallowance Deleted; Power Benchmarking, Cess, and Interest Remanded

By | August 29, 2026
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TP Adjustments, 80-IA Deductions, and Section 14A Disallowance Deleted; Power Benchmarking, Cess, and Interest Remanded Issue Whether transfer pricing adjustments on cost allocations, external CUP benchmarking for power transfer, section 80-IA disallowances, section 14A additions without exempt income, MAT cess adjustments, and section 234A interest levies are legally sustainable for AY 2020-21. Facts TP Adjustment… Read More »

Upfront Timeshare Membership Fees with Long-Term Service Obligations Cannot Be Taxed Fully in the Initial Year and Must Be Deferred over the Contract Term

By | August 29, 2026
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Upfront Timeshare Membership Fees with Long-Term Service Obligations Cannot Be Taxed Fully in the Initial Year and Must Be Deferred over the Contract Term Issue Whether upfront timeshare membership fees collected by an assessee are fully taxable in the initial year under the mercantile system of accounting, or if 55% of the fee can be… Read More »