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...
Payments of accumulated charitable income to another registered institution were treated as taxable under the deeming rule because the source of funds was accumulation and the recipient held charitable registration; the nomenclature of the transfer as project expenditure or implementation charges did not matter. The rectification under mistake apparent from record was upheld because the relevant facts were already on the assessment record and no fresh inquiry was needed, so the issue was not a debatable one or a review. A challenge based on denial of a video conference hearing in faceless appellate proceedings also failed for want of shown prejudice. Consequential interest was held mandatory and subject only to recomputation.
Payments of accumulated charitable income to another registered institution were treated as taxable under the deeming rule because the source of funds was accumulation and the recipient held charitable registration; the nomenclature of the transfer as project expenditure or implementation charges did not matter. The rectification under mistake apparent from record was upheld because the relevant facts were already on the assessment record and no fresh inquiry was needed, so the issue was not a debatable one or a review. A challenge based on denial of a video conference hearing in faceless appellate proceedings also failed for want of shown prejudice. Consequential interest was held mandatory and subject only to recomputation.
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