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 provision for ex gratia payment to employees on mercantile basis was allowable as business expenditure under section 37(1) because the Board had approved the liability and government approval for release did not make it contingent; the disallowance was deleted. In respect of exempt dividend income, disallowance under section 14A read with rule 8D failed because the Assessing Officer did not first examine the assessee's claim and record dissatisfaction on the basis of the accounts; that disallowance was deleted. Expenditure for increasing authorised share capital was held to be capital in nature and outside section 35D, so the disallowance was sustained. Penalty under section 271(1)(c) was deleted because the underlying issue was debatable and had been admitted by the High Court.
A provision for ex gratia payment to employees on mercantile basis was allowable as business expenditure under section 37(1) because the Board had approved the liability and government approval for release did not make it contingent; the disallowance was deleted. In respect of exempt dividend income, disallowance under section 14A read with rule 8D failed because the Assessing Officer did not first examine the assessee's claim and record dissatisfaction on the basis of the accounts; that disallowance was deleted. Expenditure for increasing authorised share capital was held to be capital in nature and outside section 35D, so the disallowance was sustained. Penalty under section 271(1)(c) was deleted because the underlying issue was debatable and had been admitted by the High Court.
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