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...
Educational trust exemption was sustained despite allegations that development fee collections and surplus indicated capitation fee or profit motive, because the prior year's finding that the assessee was charitable and engaged in education had already been affirmed, and no fresh distinguishing material or proved violation of the capitation fee law was shown. Depreciation on trust assets remained allowable for A.Y. 2014-15, since section 11(6) operates prospectively from A.Y. 2015-16 and depreciation is part of real income computation; the disallowance failed. Capital gains exemption under section 11(1A) was also allowed on compulsory acquisition proceeds, as reinvestment in new capital assets is tested on substance and does not require strict fund-to-fund tracing, with proportionate relief available.
Educational trust exemption was sustained despite allegations that development fee collections and surplus indicated capitation fee or profit motive, because the prior year's finding that the assessee was charitable and engaged in education had already been affirmed, and no fresh distinguishing material or proved violation of the capitation fee law was shown. Depreciation on trust assets remained allowable for A.Y. 2014-15, since section 11(6) operates prospectively from A.Y. 2015-16 and depreciation is part of real income computation; the disallowance failed. Capital gains exemption under section 11(1A) was also allowed on compulsory acquisition proceeds, as reinvestment in new capital assets is tested on substance and does not require strict fund-to-fund tracing, with proportionate relief available.
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