Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Rectification was held maintainable where the earlier appellate direction wrongly assumed that land cost had not already been debited in the assessee's accounts and, under the joint development arrangement, treated construction cost as the assessee's cost. The Tribunal held that no provision allowed substitution of actual cost with fair market value or another notional value for computing profits for section 80-IB(10), so the deduction had to be recomputed on the profits disclosed in the Profit and Loss Account. It also held that the doctrine of merger did not apply because the earlier round had decided only eligibility in principle, not quantification, making rejection of rectification on merger grounds unjustified.
Rectification was held maintainable where the earlier appellate direction wrongly assumed that land cost had not already been debited in the assessee's accounts and, under the joint development arrangement, treated construction cost as the assessee's cost. The Tribunal held that no provision allowed substitution of actual cost with fair market value or another notional value for computing profits for section 80-IB(10), so the deduction had to be recomputed on the profits disclosed in the Profit and Loss Account. It also held that the doctrine of merger did not apply because the earlier round had decided only eligibility in principle, not quantification, making rejection of rectification on merger grounds unjustified.
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