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...
Foreign exchange gain from realization of export proceeds for IT/ITES services rendered to associated enterprises was treated as operating income under TNMM, because it arose on revenue account in the normal course of business; the Assessing Officer was directed to verify this linkage, and the remaining transfer pricing grounds were left academic. Donation to Odisha State Disaster Management Authority was held eligible for deduction under section 80G despite being part of CSR expenditure, as there is no general bar outside the statutory exclusions. The foreign tax credit claim under section 90 was restored for verification and consequential grant in accordance with law.
Foreign exchange gain from realization of export proceeds for IT/ITES services rendered to associated enterprises was treated as operating income under TNMM, because it arose on revenue account in the normal course of business; the Assessing Officer was directed to verify this linkage, and the remaining transfer pricing grounds were left academic. Donation to Odisha State Disaster Management Authority was held eligible for deduction under section 80G despite being part of CSR expenditure, as there is no general bar outside the statutory exclusions. The foreign tax credit claim under section 90 was restored for verification and consequential grant in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
