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...
Rental receipts from furnished premises were treated as income from house property because the leave and licence arrangement showed a letting for rent with only incidental facilities, not a systematic commercial business of running a centre; GST collected on the rent did not change the tax character, and standard deduction under section 24(a) followed. The claim for interest deduction on borrowings used to acquire another property was not decided on merits because the record lacked key facts on the purpose, use, and income treatment of that property, so the issue was remanded for fresh enquiry.
Rental receipts from furnished premises were treated as income from house property because the leave and licence arrangement showed a letting for rent with only incidental facilities, not a systematic commercial business of running a centre; GST collected on the rent did not change the tax character, and standard deduction under section 24(a) followed. The claim for interest deduction on borrowings used to acquire another property was not decided on merits because the record lacked key facts on the purpose, use, and income treatment of that property, so the issue was remanded for fresh enquiry.
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