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...
The note records an ITAT ruling on banking and employee-benefit tax issues. Actuarially valued pension, leave-travel/home-travel, and other long-term employee benefit provisions were treated as ascertained liabilities and allowed, while privilege leave encashment remained deductible only on actual payment. Interest on NPAs and non-performing investments was taxed only on real income, and securities in AFS/HFT/HTM categories were accepted at lower of cost or market value. The Tribunal also held that MAT does not apply to corresponding new banks, upheld business-expediency deductions for staff welfare and retired employees' medical benefits, and remitted or rejected several claims for lack of verification or supporting material.
The note records an ITAT ruling on banking and employee-benefit tax issues. Actuarially valued pension, leave-travel/home-travel, and other long-term employee benefit provisions were treated as ascertained liabilities and allowed, while privilege leave encashment remained deductible only on actual payment. Interest on NPAs and non-performing investments was taxed only on real income, and securities in AFS/HFT/HTM categories were accepted at lower of cost or market value. The Tribunal also held that MAT does not apply to corresponding new banks, upheld business-expediency deductions for staff welfare and retired employees' medical benefits, and remitted or rejected several claims for lack of verification or supporting material.
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