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...
Depreciation on franchise rights was allowed on the full actual cost of the intangible asset, because the franchise licence was acquired when the agreement was executed and annual instalments did not limit the asset's cost; any later adjustment would affect subsequent years. Cash payments for daily allowances were disallowed under section 40A(3) because the relevant test is the actual payment to a person in a day, and no Rule 6DD exception was proved. Business research and routed remuneration claims failed for want of proof of actual services and business nexus, while the ad hoc percentage disallowance of web support expenses was deleted for lack of evidentiary basis. Security expenses were allowed on commercial expediency, and several reimbursement, TDS credit and brought-forward loss issues were remanded for verification.
Depreciation on franchise rights was allowed on the full actual cost of the intangible asset, because the franchise licence was acquired when the agreement was executed and annual instalments did not limit the asset's cost; any later adjustment would affect subsequent years. Cash payments for daily allowances were disallowed under section 40A(3) because the relevant test is the actual payment to a person in a day, and no Rule 6DD exception was proved. Business research and routed remuneration claims failed for want of proof of actual services and business nexus, while the ad hoc percentage disallowance of web support expenses was deleted for lack of evidentiary basis. Security expenses were allowed on commercial expediency, and several reimbursement, TDS credit and brought-forward loss issues were remanded for verification.
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