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...
Addition under section 56(2)(viib) on CCPS premium was deleted where the shares were issued under a reorganisation to the parent and existing shareholders, the valuation was supported by registered valuers or a merchant banker under Rule 11UA, and the transaction was not shown to be unaccounted money. The Tribunal also held that conversion of earlier CCPS into equity during the year did not attract section 56(2)(viib) for that assessment year. A year-end management fee reversal was remanded for fresh verification because the explanation lacked supporting evidence. Payments to MTH for transformation and related hotel services were held revenue in nature, and section 40A(2) was found inapplicable.
Addition under section 56(2)(viib) on CCPS premium was deleted where the shares were issued under a reorganisation to the parent and existing shareholders, the valuation was supported by registered valuers or a merchant banker under Rule 11UA, and the transaction was not shown to be unaccounted money. The Tribunal also held that conversion of earlier CCPS into equity during the year did not attract section 56(2)(viib) for that assessment year. A year-end management fee reversal was remanded for fresh verification because the explanation lacked supporting evidence. Payments to MTH for transformation and related hotel services were held revenue in nature, and section 40A(2) was found inapplicable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
