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...
Royalty expenditure and subcontract expenditure were both restored to the Assessing Officer for fresh examination because the existing record did not conclusively establish the contractual basis, the nature of royalty deduction from running bills, or the genuineness of the joint venture arrangement and subcontracting arrangement. The Tribunal required reconsideration of the royalty claim on the basis of the contract terms and material already filed, and directed verification of the subcontract disallowance with reference to TDS compliance, the joint venture agreement, and execution of work under the PWD tender. Since the quantum additions were set aside for de novo assessment, the consequential penalty under section 270A was also left open for fresh consideration in the reassessment proceedings.
Royalty expenditure and subcontract expenditure were both restored to the Assessing Officer for fresh examination because the existing record did not conclusively establish the contractual basis, the nature of royalty deduction from running bills, or the genuineness of the joint venture arrangement and subcontracting arrangement. The Tribunal required reconsideration of the royalty claim on the basis of the contract terms and material already filed, and directed verification of the subcontract disallowance with reference to TDS compliance, the joint venture agreement, and execution of work under the PWD tender. Since the quantum additions were set aside for de novo assessment, the consequential penalty under section 270A was also left open for fresh consideration in the reassessment proceedings.
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