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...
Transactions with a wholly owned pass-through foreign LLC, whose profits were already taxed in India, were treated as self-dealing rather than separate AE dealings, so no arm's length adjustment survived and the sale adjustment was deleted. Receivables from that same entity were held intrinsically linked to the underlying sales, so the separate interest adjustment was also deleted. For specified domestic transactions, the altered TNMM filters and reduced comparables were found unjustified; the eligible unit's margin fell within the existing range, so the recomputation of profits and related deduction reduction were deleted. The standalone challenge to initiation of penalty proceedings was dismissed as premature.
Transactions with a wholly owned pass-through foreign LLC, whose profits were already taxed in India, were treated as self-dealing rather than separate AE dealings, so no arm's length adjustment survived and the sale adjustment was deleted. Receivables from that same entity were held intrinsically linked to the underlying sales, so the separate interest adjustment was also deleted. For specified domestic transactions, the altered TNMM filters and reduced comparables were found unjustified; the eligible unit's margin fell within the existing range, so the recomputation of profits and related deduction reduction were deleted. The standalone challenge to initiation of penalty proceedings was dismissed as premature.
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