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...
Arrears of the employer's contribution to an approved superannuation fund, though taxable as a perquisite, formed part of salary for relief on income received in arrears. The Tribunal held that relief for salary received in arrears extends to arrears of perquisites included in salary, and that Rule 21A and Form 10E apply to such claims under Rule 21A(1)(a) read with Rule 21A(2), not the residuary provision. An internal circular treating the amount as a perquisite could not override the Act. The assessee was therefore entitled to relief and the claim had to be allowed.
Arrears of the employer's contribution to an approved superannuation fund, though taxable as a perquisite, formed part of salary for relief on income received in arrears. The Tribunal held that relief for salary received in arrears extends to arrears of perquisites included in salary, and that Rule 21A and Form 10E apply to such claims under Rule 21A(1)(a) read with Rule 21A(2), not the residuary provision. An internal circular treating the amount as a perquisite could not override the Act. The assessee was therefore entitled to relief and the claim had to be allowed.
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