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...
Ad hoc restriction of employee benefit expenditure requires reconciliation of salary details, vouchers, service evidence and business nexus, rather than comparison with revenue alone. Share premium additions turn on substantiation of fair market value under the valuation framework, and an incorrect statutory label does not displace the substance of the addition where no valuation report is produced. ESOP discount is recognised as employee compensation and potentially allowable as business expenditure, but the claim must be supported by valuation and grant-wise working. Loss on sale of subsidiary investment may be treated as business loss only where commercial expediency is established, and additional evidence must comply with Rule 46A and natural justice.
Ad hoc restriction of employee benefit expenditure requires reconciliation of salary details, vouchers, service evidence and business nexus, rather than comparison with revenue alone. Share premium additions turn on substantiation of fair market value under the valuation framework, and an incorrect statutory label does not displace the substance of the addition where no valuation report is produced. ESOP discount is recognised as employee compensation and potentially allowable as business expenditure, but the claim must be supported by valuation and grant-wise working. Loss on sale of subsidiary investment may be treated as business loss only where commercial expediency is established, and additional evidence must comply with Rule 46A and natural justice.
Note: It is a system-generated summary and is for quick reference only.
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