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...
Dispute concerned computation of interest in the intimation issued under s. 143(1), not the leviability of interest itself. The ITAT noted that interest under ss. 234A and 234C was not in dispute, but the assessee challenged the higher amounts computed in the intimation. Because the working for the enhanced figure, especially for s. 234C, was not on record and the balance had to be examined against advance tax paid, the matter required factual verification. The computation under ss. 234A, 234B and 234C was restored to the AO for de novo adjudication in accordance with law.
Dispute concerned computation of interest in the intimation issued under s. 143(1), not the leviability of interest itself. The ITAT noted that interest under ss. 234A and 234C was not in dispute, but the assessee challenged the higher amounts computed in the intimation. Because the working for the enhanced figure, especially for s. 234C, was not on record and the balance had to be examined against advance tax paid, the matter required factual verification. The computation under ss. 234A, 234B and 234C was restored to the AO for de novo adjudication in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
