Transfer Pricing

Arm’s Length Principle — TNMM is the most appropriate method of determining ALP when the services rendered by the assessee falls under the category of installation services, warranty services …

Reassessment

When the orders of the AO merge with that of appellate authorities, the AO loses his jurisdiction to reopen the assessment, as held by MumTrib in ACIT v BSES …

Deduction under s 35E

The expenses must have been incurred wholly and exclusively for “exploring, locating or proving deposits of any minerals, and includes such operations which prove to be infructuous or abortive” …

Business Expenditure

Provision for warranty on eligible sales made during the relevant previous year is an ascertained liability and allowable as a deduction — as held by DelTrib in Woodward Governor …

Exemption under s 11

Exemption under s 11 cannot be denied to charitable trust/society merely because it is making systematic profit, even though the profit is utilised only for charitable purpose — as …

Reassessment

Change of opinion — The reopening of assessment by AO is invalid where AO had examined the question whether the loss in F and O transactions could be set …

Revision

The limitation for exercising jurisdiction under s 263 would not start from the assessment under s 143(1) of the IT Act but would start only from the order passed …

Assessment

Notice under s 143(2) — Service of notice by post shall be deemed to be effected where the envelope has been properly addressed, proper stamps affixed and posted by …