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...
Interest merged into a decree and payable in execution retains the character of a judgment debt, so the judgment debtor cannot deduct tax at source from the decretal interest unless the decree itself authorises such deduction. The court applied the principle that a decree must be executed as it stands, subject only to adjustments permitted under the Civil Procedure Code, and held that section 195 did not extend to a decretal debt. The deduction already made toward TDS was therefore upheld, and the challenge failed.
Interest merged into a decree and payable in execution retains the character of a judgment debt, so the judgment debtor cannot deduct tax at source from the decretal interest unless the decree itself authorises such deduction. The court applied the principle that a decree must be executed as it stands, subject only to adjustments permitted under the Civil Procedure Code, and held that section 195 did not extend to a decretal debt. The deduction already made toward TDS was therefore upheld, and the challenge failed.
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