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...
Annual IPL franchise fee was treated as revenue expenditure because it only enabled participation for the year and did not create an enduring asset; the Revenue challenge failed. Travel, hospitality and related match-arrangement expenses were sustained as business expenditure, subject only to limited verification of supporting bills. Website development expense was also allowed as revenue in nature. Club membership expenditure used for business meetings and interactions was held allowable under section 37(1). Salary provision under mercantile accounting and bonus paid before the return filing due date were held to be accrued and allowable liabilities, so the disallowance was deleted. The Revenue appeals were dismissed.
Annual IPL franchise fee was treated as revenue expenditure because it only enabled participation for the year and did not create an enduring asset; the Revenue challenge failed. Travel, hospitality and related match-arrangement expenses were sustained as business expenditure, subject only to limited verification of supporting bills. Website development expense was also allowed as revenue in nature. Club membership expenditure used for business meetings and interactions was held allowable under section 37(1). Salary provision under mercantile accounting and bonus paid before the return filing due date were held to be accrued and allowable liabilities, so the disallowance was deleted. The Revenue appeals were dismissed.
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