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...
A genuine donation made by cheque to an approved institution remained substantively eligible for deduction, and the claim could not be refused merely because the wrong deduction provision was quoted. The Tribunal held that a technical misdescription of the provision did not defeat relief where the facts already on record established eligibility and allowing the claim under the correct provision caused no adverse effect on total income. It also recognised that appellate authority could grant the proper relief on the existing material, so the disallowance was unsustainable and was directed to be deleted.
A genuine donation made by cheque to an approved institution remained substantively eligible for deduction, and the claim could not be refused merely because the wrong deduction provision was quoted. The Tribunal held that a technical misdescription of the provision did not defeat relief where the facts already on record established eligibility and allowing the claim under the correct provision caused no adverse effect on total income. It also recognised that appellate authority could grant the proper relief on the existing material, so the disallowance was unsustainable and was directed to be deleted.
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