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...
Interest arising on internal placements between an Indian branch and its head office or overseas branches was treated as a payment to self and not taxable income; interest from other overseas banks also escaped tax because the statutory condition for source-based taxation was not met, and the specific interest provision excluded resort to the general charging provision. Disallowances under section 14A failed where concessional-rate interest remained taxable, and also where interest-free funds covered exempt-income investments. Broken period interest on securities held as stock-in-trade, year-end foreign exchange revaluation loss, club membership fee for employees, and CRR/SLR shortfall payment were all held allowable. Interest charged on refund processing was not sustained, and bad debt write-back was remitted only for verification of prior taxation.
Interest arising on internal placements between an Indian branch and its head office or overseas branches was treated as a payment to self and not taxable income; interest from other overseas banks also escaped tax because the statutory condition for source-based taxation was not met, and the specific interest provision excluded resort to the general charging provision. Disallowances under section 14A failed where concessional-rate interest remained taxable, and also where interest-free funds covered exempt-income investments. Broken period interest on securities held as stock-in-trade, year-end foreign exchange revaluation loss, club membership fee for employees, and CRR/SLR shortfall payment were all held allowable. Interest charged on refund processing was not sustained, and bad debt write-back was remitted only for verification of prior taxation.
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