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...
Employee travel, hospitality, conveyance, tickets, goods, and hotel boarding expenses were held to fall within the statutory heads of fringe benefits under section 115WB(1)(b) read with section 115WB(2), so the Tribunal upheld the quantum assessment on those items. The Commissioner (Appeals) was also found to have issued only a limited consequential direction to verify tax already paid and finalise computation, not an impermissible fresh remand on merits. On penalty, the Tribunal sustained cancellation under section 271(1)(d), holding that rejection of the assessee's exclusion claim in quantum proceedings did not by itself establish inaccurate particulars, following Reliance Petroproducts.
Employee travel, hospitality, conveyance, tickets, goods, and hotel boarding expenses were held to fall within the statutory heads of fringe benefits under section 115WB(1)(b) read with section 115WB(2), so the Tribunal upheld the quantum assessment on those items. The Commissioner (Appeals) was also found to have issued only a limited consequential direction to verify tax already paid and finalise computation, not an impermissible fresh remand on merits. On penalty, the Tribunal sustained cancellation under section 271(1)(d), holding that rejection of the assessee's exclusion claim in quantum proceedings did not by itself establish inaccurate particulars, following Reliance Petroproducts.
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