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...
ITAT held that exemption under section 10(46) depends on the nature of the receipt and not on the year in which it is recognised in the accounts. Prior period regulatory receipts such as licence fees, advances and other regulatory income remained exempt because they were intrinsically linked to the statutory functions of the Commission, and the corresponding addition was deleted. The Tribunal also held that incidental non-commercial receipts, including interest on House Building Advance, personal use of office vehicle, miscellaneous income and related interest receipts, were ancillary to the exempt regulatory activity and retained their exempt character. The additions on both counts were therefore unsustainable and were directed to be deleted.
ITAT held that exemption under section 10(46) depends on the nature of the receipt and not on the year in which it is recognised in the accounts. Prior period regulatory receipts such as licence fees, advances and other regulatory income remained exempt because they were intrinsically linked to the statutory functions of the Commission, and the corresponding addition was deleted. The Tribunal also held that incidental non-commercial receipts, including interest on House Building Advance, personal use of office vehicle, miscellaneous income and related interest receipts, were ancillary to the exempt regulatory activity and retained their exempt character. The additions on both counts were therefore unsustainable and were directed to be deleted.
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