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...
Interest income under the mercantile system was held taxable in AY 2007-08 on accrual basis because the assessee, having followed that method, had to bring the entire accrued amount to tax in that year and produced no corroborative material showing that accrual had been deferred by litigation or other valid reason. The Tribunal also upheld reopening under section 147, holding that the original assessment had not examined the balance accrued interest and that information from remand proceedings constituted tangible material; the plea of mere change of opinion therefore failed. To avoid double taxation, it approved verification and rectification in AY 2009-10 if the amount had been declared there.
Interest income under the mercantile system was held taxable in AY 2007-08 on accrual basis because the assessee, having followed that method, had to bring the entire accrued amount to tax in that year and produced no corroborative material showing that accrual had been deferred by litigation or other valid reason. The Tribunal also upheld reopening under section 147, holding that the original assessment had not examined the balance accrued interest and that information from remand proceedings constituted tangible material; the plea of mere change of opinion therefore failed. To avoid double taxation, it approved verification and rectification in AY 2009-10 if the amount had been declared there.
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