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...
Contribution paid to an insurer under a leave encashment scheme is treated as actual business expenditure, distinct from a mere provision, and CSR spending mandated under port guidelines is viewed as business-linked, with the statutory disallowance operating prospectively. Disputed enhanced estate rentals are not taxable as real income where recoverability remains uncertain, and port infrastructure such as docks, sea walls, piers and railway assets may qualify as plant under the functional test for depreciation. Consequential disallowance for short deduction of tax at source falls once the underlying TDS default is deleted, and employee welfare and labour-related contributions are allowable where made for commercial expediency.
Contribution paid to an insurer under a leave encashment scheme is treated as actual business expenditure, distinct from a mere provision, and CSR spending mandated under port guidelines is viewed as business-linked, with the statutory disallowance operating prospectively. Disputed enhanced estate rentals are not taxable as real income where recoverability remains uncertain, and port infrastructure such as docks, sea walls, piers and railway assets may qualify as plant under the functional test for depreciation. Consequential disallowance for short deduction of tax at source falls once the underlying TDS default is deleted, and employee welfare and labour-related contributions are allowable where made for commercial expediency.
Note: It is a system-generated summary and is for quick reference only.
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