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...
Bad debt deduction is allowable where the assessee has written off the dues in its accounts as irrecoverable; under the amended law, further proof that the debt had actually become irrecoverable is not required, and the Tribunal deleted the disallowance by following T.R.F. Ltd. Estimated business expense disallowance based on fixed percentages of transportation and vehicle-related es, without comparable material or a reasoned basis, was held arbitrary and unsustainable; the 10% addition was deleted. The assessee's appeal was allowed.
Bad debt deduction is allowable where the assessee has written off the dues in its accounts as irrecoverable; under the amended law, further proof that the debt had actually become irrecoverable is not required, and the Tribunal deleted the disallowance by following T.R.F. Ltd. Estimated business expense disallowance based on fixed percentages of transportation and vehicle-related es, without comparable material or a reasoned basis, was held arbitrary and unsustainable; the 10% addition was deleted. The assessee's appeal was allowed.
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