“Section 264(2)”

Reassessment proceedings initiated under Section 147 beyond four years from the end of the relevant assessment year are invalid unless the assessee failed to disclose fully and truly all material facts necessary for assessment. Without such failure, the notice issued under Section 148 is time-barred and without jurisdiction.

When an assessee possesses sufficient interest-free funds, it is presumed that any interest-free advances or investments made are from these funds, preventing disallowance of interest under Section 36(1)(iii). This principle applies if own capital and interest-free loans exceed the interest-free advances given.

The determination of Arm's Length Price (ALP) for international transactions involving debt requires consideration of both the amount on which interest should be charged and the arm's length rate for that interest. Guidelines are provided for computing the ALP of the international transaction of 'debt arising during the course of business.'

Registration of a charitable trust under Section 12A/12AA is deemed to have taken effect from six months after the application date if the revenue does not respond within that period.

A dependent agent can create a permanent establishment (PE) in India, and profits attributable to that PE can be taxed in India.

Deemed dividends under Section 2(22)(e) can only be taxed in the hands of shareholders who are both registered and beneficial owners of shares in the paying company.