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...
Deduction under section 36(1)(vii) was held to operate distinctly from provision-based deduction under section 36(1)(viia), and the proviso was applied only to prevent double deduction; on the facts already accepted in earlier years, no duplication was shown, so the disallowance of bad debts written off was deleted. The Tribunal also held that earlier coordinate bench rulings remained binding despite pending High Court appeals in the absence of any stay or reversal, and the Revenue's challenge failed. On the amortised lease premium issue, the Tribunal applied section 158A because an identical question of law was already pending before the High Court, and directed that the final High Court decision be applied to the years in appeal.
Deduction under section 36(1)(vii) was held to operate distinctly from provision-based deduction under section 36(1)(viia), and the proviso was applied only to prevent double deduction; on the facts already accepted in earlier years, no duplication was shown, so the disallowance of bad debts written off was deleted. The Tribunal also held that earlier coordinate bench rulings remained binding despite pending High Court appeals in the absence of any stay or reversal, and the Revenue's challenge failed. On the amortised lease premium issue, the Tribunal applied section 158A because an identical question of law was already pending before the High Court, and directed that the final High Court decision be applied to the years in appeal.
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