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 on borrowed capital is deductible under section 36(1)(iii) only when the borrowing is for the assessee's own business or profession. Where the borrowed funds were invested by an individual as capital contribution in a partnership firm, and the business was carried on by the firm rather than by the individual, the statutory condition was not met. The claim, if available at all, would arise at the level of the firm and not in the individual partner's assessment. The deduction was therefore rightly disallowed, and the appeal was dismissed.
Interest on borrowed capital is deductible under section 36(1)(iii) only when the borrowing is for the assessee's own business or profession. Where the borrowed funds were invested by an individual as capital contribution in a partnership firm, and the business was carried on by the firm rather than by the individual, the statutory condition was not met. The claim, if available at all, would arise at the level of the firm and not in the individual partner's assessment. The deduction was therefore rightly disallowed, and the appeal was dismissed.
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