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...
CBDT condones the delay in electronically filing Form No. 10AB for approval under clause (ii) of the first proviso to section 80G(5) where the form was furnished between 01.10.2025 and 31.03.2026, and authorises the jurisdictional Principal Commissioner or Commissioner to decide such applications on merits by 31.12.2026. Applications already rejected only because they were filed after 30.09.2025 are deemed to have had the delay condoned and must also be disposed of on merits by that date. The circular does not create any automatic entitlement to approval.
CBDT condones the delay in electronically filing Form No. 10AB for approval under clause (ii) of the first proviso to section 80G(5) where the form was furnished between 01.10.2025 and 31.03.2026, and authorises the jurisdictional Principal Commissioner or Commissioner to decide such applications on merits by 31.12.2026. Applications already rejected only because they were filed after 30.09.2025 are deemed to have had the delay condoned and must also be disposed of on merits by that date. The circular does not create any automatic entitlement to approval.
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