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...
Rectification of a return could not be used to enhance business income where amounts such as rent, dividend and bank interest had already been disclosed under their proper heads, because the same sums were again added to business income due to a return-filing error. On examining the return, profit and loss account and computation, the Tribunal accepted that income taxable under other heads had to be reduced from business income when computing net profit. The rectification order was based on an incorrect appreciation of the computation, and the impugned addition was deleted.
Rectification of a return could not be used to enhance business income where amounts such as rent, dividend and bank interest had already been disclosed under their proper heads, because the same sums were again added to business income due to a return-filing error. On examining the return, profit and loss account and computation, the Tribunal accepted that income taxable under other heads had to be reduced from business income when computing net profit. The rectification order was based on an incorrect appreciation of the computation, and the impugned addition was deleted.
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