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...
Provision for repair of unserviceable spare parts in an airline business was treated as an allowable business expenditure rather than a mere contingent liability, because the Tribunal found the inventory and repair outgo to be part of the ordinary recurring business cycle and accepted estimation-based provisioning under Bharat Earth Movers and Chainrup Sampatram. The disallowance was deleted, subject to proper computation in accordance with law. The claim for provision for obsolescence of Bid & Win inventory was rejected for the year under appeal, as the Department stated it had been accepted in the succeeding assessment year. Other disallowance grounds were not pressed before the CIT(A).
Provision for repair of unserviceable spare parts in an airline business was treated as an allowable business expenditure rather than a mere contingent liability, because the Tribunal found the inventory and repair outgo to be part of the ordinary recurring business cycle and accepted estimation-based provisioning under Bharat Earth Movers and Chainrup Sampatram. The disallowance was deleted, subject to proper computation in accordance with law. The claim for provision for obsolescence of Bid & Win inventory was rejected for the year under appeal, as the Department stated it had been accepted in the succeeding assessment year. Other disallowance grounds were not pressed before the CIT(A).
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