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...
In transfer pricing for sale of goods to associated enterprises, the Tribunal accepted TNMM at entity level and rejected the internal cost plus method because earlier coordinate bench decisions on identical facts had already approved TNMM, and no material factual change was shown; the transfer pricing adjustment was deleted. On reversal of provisions, it held that amounts already disallowed when created cannot be taxed again on reversal, but remitted the issue to the Assessing Officer for verification of the claimed accounting mismatch and reconciliation. For short grant of TDS/TCS credit, it directed factual verification from Form 26AS, AIS and supporting records, with due credit to be allowed in accordance with law.
In transfer pricing for sale of goods to associated enterprises, the Tribunal accepted TNMM at entity level and rejected the internal cost plus method because earlier coordinate bench decisions on identical facts had already approved TNMM, and no material factual change was shown; the transfer pricing adjustment was deleted. On reversal of provisions, it held that amounts already disallowed when created cannot be taxed again on reversal, but remitted the issue to the Assessing Officer for verification of the claimed accounting mismatch and reconciliation. For short grant of TDS/TCS credit, it directed factual verification from Form 26AS, AIS and supporting records, with due credit to be allowed in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
