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...
Broken period amount received on transfer of non-convertible debentures retained the character of interest, even though it was paid by the purchaser rather than the issuer, because the NCDs were transferred on a cum-interest basis and the amount represented accrued return for the intervening period. The Tribunal held that the source of payment did not change the intrinsic character of the receipt. The amount was therefore assessable as interest under the head 'Income from Other Sources', and the assessee's appeal failed.
Broken period amount received on transfer of non-convertible debentures retained the character of interest, even though it was paid by the purchaser rather than the issuer, because the NCDs were transferred on a cum-interest basis and the amount represented accrued return for the intervening period. The Tribunal held that the source of payment did not change the intrinsic character of the receipt. The amount was therefore assessable as interest under the head 'Income from Other Sources', and the assessee's appeal failed.
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