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...
Audited financial statements separately disclosed agricultural income and non-agricultural income, with the non-agricultural component offered to tax and the agricultural income claimed exempt. The Tribunal held that the first appellate authority proceeded on an incorrect factual premise in stating that no bifurcation existed. Because the audited statements were before the assessing and appellate authorities and the income and expenditure figures were not disputed, the claim of exempt agricultural income was accepted. The addition made by treating the agricultural income as business income was deleted.
Audited financial statements separately disclosed agricultural income and non-agricultural income, with the non-agricultural component offered to tax and the agricultural income claimed exempt. The Tribunal held that the first appellate authority proceeded on an incorrect factual premise in stating that no bifurcation existed. Because the audited statements were before the assessing and appellate authorities and the income and expenditure figures were not disputed, the claim of exempt agricultural income was accepted. The addition made by treating the agricultural income as business income was deleted.
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