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...
Rule 27 permits a respondent to support the appellate order on an additional ground, and the alleged allotment breach could not justify disallowance in Assessment Year 2011-12 because the Revenue's material related to a later year. On the merits, the Revenue failed to prove breach of the beneficial housing-project deduction condition under section 80IB(10)(f): it relied mainly on a third-party statement, produced no reliable documentary evidence that the flats were really allotted to one person through nominees, and was denied effective cross-examination. The Tribunal treated the statutory condition as requiring cogent proof and sustained deletion of the disallowance; the Revenue's appeal for Assessment Year 2012-13 was rejected on the same reasoning.
Rule 27 permits a respondent to support the appellate order on an additional ground, and the alleged allotment breach could not justify disallowance in Assessment Year 2011-12 because the Revenue's material related to a later year. On the merits, the Revenue failed to prove breach of the beneficial housing-project deduction condition under section 80IB(10)(f): it relied mainly on a third-party statement, produced no reliable documentary evidence that the flats were really allotted to one person through nominees, and was denied effective cross-examination. The Tribunal treated the statutory condition as requiring cogent proof and sustained deletion of the disallowance; the Revenue's appeal for Assessment Year 2012-13 was rejected on the same reasoning.
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