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...
Interest provision based on an arbitral award was disallowed because the Supreme Court's setting aside of that award extinguished the underlying liability, so the claim had to be reconsidered on the footing that no such interest was payable. Expenditure on gifts, boarding, lodging and allied arrangements for a General Body Meeting was held to be business expenditure under a purposive reading of section 37, since convening such a meeting was a statutory requirement and the Assessing Officer could not reject the claim merely as excessive once its business purpose was established. The Tribunal's allowance of that expenditure was affirmed, while the interest provision deduction was rejected.
Interest provision based on an arbitral award was disallowed because the Supreme Court's setting aside of that award extinguished the underlying liability, so the claim had to be reconsidered on the footing that no such interest was payable. Expenditure on gifts, boarding, lodging and allied arrangements for a General Body Meeting was held to be business expenditure under a purposive reading of section 37, since convening such a meeting was a statutory requirement and the Assessing Officer could not reject the claim merely as excessive once its business purpose was established. The Tribunal's allowance of that expenditure was affirmed, while the interest provision deduction was rejected.
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