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...
Surrendered income offered during a survey was accepted as business income at normal rates, and the Tribunal held that the enhanced tax rate under section 115BBE could not be applied for AY 2017-18. Relying on later High Court authority, it treated the higher rate as prospective from 01.04.2017, relevant from AY 2018-19 onwards, and therefore inapplicable to the year in issue. The surrendered sum was directed to be taxed only at normal rates, not at the enhanced rate under section 115BBE.
Surrendered income offered during a survey was accepted as business income at normal rates, and the Tribunal held that the enhanced tax rate under section 115BBE could not be applied for AY 2017-18. Relying on later High Court authority, it treated the higher rate as prospective from 01.04.2017, relevant from AY 2018-19 onwards, and therefore inapplicable to the year in issue. The surrendered sum was directed to be taxed only at normal rates, not at the enhanced rate under section 115BBE.
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