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...
Section 43B could not be applied to unpaid GST where the assessee had not debited the liability to the profit and loss account and had not claimed it as expenditure. The Tribunal noted that the appellate order itself recorded no deduction claim, yet the adjustment was sustained on the basis that GST formed part of turnover. It held that, absent a deduction otherwise claimed, there was no legal basis to invoke section 43B in this manner. The disallowance of the unpaid GST liability was therefore deleted.
Section 43B could not be applied to unpaid GST where the assessee had not debited the liability to the profit and loss account and had not claimed it as expenditure. The Tribunal noted that the appellate order itself recorded no deduction claim, yet the adjustment was sustained on the basis that GST formed part of turnover. It held that, absent a deduction otherwise claimed, there was no legal basis to invoke section 43B in this manner. The disallowance of the unpaid GST liability was therefore deleted.
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