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...
Predominant trading activity in the healthcare segment justified excluding two manufacturing comparables, because the assessee's functional profile, assets employed and risks assumed differed materially from manufacturers; that exclusion was upheld for both assessment years on the same facts. For intra-group IT support services, maintenance-related charges for an already implemented IT infrastructure were accepted on the same footing as the earlier year, so the arm's length price could not be determined at nil and the transfer pricing adjustment was deleted.
Predominant trading activity in the healthcare segment justified excluding two manufacturing comparables, because the assessee's functional profile, assets employed and risks assumed differed materially from manufacturers; that exclusion was upheld for both assessment years on the same facts. For intra-group IT support services, maintenance-related charges for an already implemented IT infrastructure were accepted on the same footing as the earlier year, so the arm's length price could not be determined at nil and the transfer pricing adjustment was deleted.
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