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 related-party slump sale capital loss was disallowed because the assessee failed to prove genuineness, valuation basis and fair consideration through independent material, and the claimed loss was not supported beyond book entries. Compensation received on the departure of a key medical professional was taxed as revenue receipt because the hospital's profit-earning apparatus remained intact and the payment was linked to anticipated business loss rather than destruction of a capital source. The Tribunal also upheld deletion of interest disallowance and interest capitalisation additions on the footing that the assessee had sufficient own funds. Section 14A was held inapplicable because no exempt income was earned during the year.
A related-party slump sale capital loss was disallowed because the assessee failed to prove genuineness, valuation basis and fair consideration through independent material, and the claimed loss was not supported beyond book entries. Compensation received on the departure of a key medical professional was taxed as revenue receipt because the hospital's profit-earning apparatus remained intact and the payment was linked to anticipated business loss rather than destruction of a capital source. The Tribunal also upheld deletion of interest disallowance and interest capitalisation additions on the footing that the assessee had sufficient own funds. Section 14A was held inapplicable because no exempt income was earned during the year.
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