Home Highlights August 2015 Year 2015 This

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1. Best judgement assessment - There appears to be divergents views insofar as the question as to whether the consumption of electricity can constitute the sole basis for...

2. Valuation of imported goods - Related person - Merely because there were transfer of funds in India amongst three importers will not make them related persons in terms...

3. TP Adjustment - valuation of Arms Length Price (ALP) - No Arm's Length Price is required to be determined for a transaction with specified persons in section 40A(2)(b)...

4. Principles of natural justice - best judgement assessment done by ex-parte order - The Assessing Authority is bound to act in a rational manner while resorting to best...

5. Valuation of imported goods - inter-se relation having any influence on the transaction value of imports, or not - If the price declared was at arm’s length, then...

6. Best judgement assessment u/s 144 - CIT(A) wrongly substituted the best judgement of the AO with his own judgement contrary to the provisions of section 144 of the Act

7. Imposition of penalty u/s 271G - failure to furnish information or documents in respect of segmental amount relating to transaction made with AEs and non-AEs for...

8. Best judgement assessment - formulae for levying the purchase tax on the ground that separate accounts are absent - There was absolutely no necessity or need for making...

9. Scrutiny by the High Court in an appeal u/s 260A for Determination of the arm’s length price made by the Tribunal - When the determination of the arm’s length price is...

10. Excise – sale through related parties, valuation provisions applicable – tribunal order reversed by SC

11. Taxability of software sale by the US entity to Indian entities - Indian subsidiary is held as DAPE [Dependent Agent Permanent Establishment] of the assessee in India -...

12. Nature of assessment - best judgment assessment or not - the entries in the books of account varying with returns filed are relied upon and then the assessment has been...

13. Role of AO as adjudicator in making the computation - Assessment made u/s 147 r.w.s. 144 and 144B - It is clear that the Parliament intended the AO to be both...

14. Validity of Best judgment assessment - Assessment u/s 153C - since petitioner has filed a return, no best judgment assessment u/s 144 of the Act could have been passed -...

15. If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of...