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...
Recurring annual maintenance charges for optical fibre network usage were treated as revenue expenditure, while upfront connectivity fees were to be amortised on a straight-line basis over the relevant 15-year contractual term, subject to agreement-wise verification. For exempt-income disallowance, own funds in excess of investments and use of borrowed funds for business supported denial of interest disallowance; administrative disallowance was confined to investments yielding exempt income and capped by exempt income earned. The text also notes that broadband network acquisition rights, goodwill arising on amalgamation, and non-compete fee can qualify as depreciable intangible assets, and that appellate authorities may entertain additional claims when facts are already on record.
Recurring annual maintenance charges for optical fibre network usage were treated as revenue expenditure, while upfront connectivity fees were to be amortised on a straight-line basis over the relevant 15-year contractual term, subject to agreement-wise verification. For exempt-income disallowance, own funds in excess of investments and use of borrowed funds for business supported denial of interest disallowance; administrative disallowance was confined to investments yielding exempt income and capped by exempt income earned. The text also notes that broadband network acquisition rights, goodwill arising on amalgamation, and non-compete fee can qualify as depreciable intangible assets, and that appellate authorities may entertain additional claims when facts are already on record.
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