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...
Whistleblower reward received from the U.S. Securities and Exchange Commission was held taxable as income, because section 2(24) is of wide amplitude and the payment arose from arranged pursuit of whistleblower claims, legal assistance on success-fee terms, collection of material, filing of the complaint, and cooperation in the investigation. The Tribunal found a clear element of expectation and quid pro quo, so the receipt was neither gratuitous nor a windfall or capital receipt. It further held that the one-time character of the payment did not make it capital, and that the amount was at least taxable as income from other sources under section 56(1).
Whistleblower reward received from the U.S. Securities and Exchange Commission was held taxable as income, because section 2(24) is of wide amplitude and the payment arose from arranged pursuit of whistleblower claims, legal assistance on success-fee terms, collection of material, filing of the complaint, and cooperation in the investigation. The Tribunal found a clear element of expectation and quid pro quo, so the receipt was neither gratuitous nor a windfall or capital receipt. It further held that the one-time character of the payment did not make it capital, and that the amount was at least taxable as income from other sources under section 56(1).
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