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 43B for GST payable could not be denied merely because the tax audit report showed the liability as outstanding on the date of signing, where the assessee claimed payment was made before the due date for filing the return. The Tribunal held that payment after the audit report date but before the return due date can still qualify for deduction, so the adjustment made in processing the return could not stand solely on the Form 3CD disclosure. The matter was remanded for verification of the actual payment dates, and the addition was to be deleted if the GST had been paid within the statutory time limit.
Deduction under section 43B for GST payable could not be denied merely because the tax audit report showed the liability as outstanding on the date of signing, where the assessee claimed payment was made before the due date for filing the return. The Tribunal held that payment after the audit report date but before the return due date can still qualify for deduction, so the adjustment made in processing the return could not stand solely on the Form 3CD disclosure. The matter was remanded for verification of the actual payment dates, and the addition was to be deleted if the GST had been paid within the statutory time limit.
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