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 registered educational trust could not have its expenditure claim rejected solely because Form 10B was filed late and the expenditure details were not reflected in the return. The ITAT treated the lapse as procedural, held that such requirements should advance justice rather than defeat a lawful claim, and accepted that the belated audit report could be taken into account. It directed the Assessing Officer to reconsider the claim after taking Form 10B on record and after giving due opportunity in accordance with natural justice. The impugned order was set aside and the matter remanded for fresh adjudication.
A registered educational trust could not have its expenditure claim rejected solely because Form 10B was filed late and the expenditure details were not reflected in the return. The ITAT treated the lapse as procedural, held that such requirements should advance justice rather than defeat a lawful claim, and accepted that the belated audit report could be taken into account. It directed the Assessing Officer to reconsider the claim after taking Form 10B on record and after giving due opportunity in accordance with natural justice. The impugned order was set aside and the matter remanded for fresh adjudication.
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