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...
Online gaming receipts were held to be taxable only on net winnings, not on a gross figure isolated from the gaming platform data; where BuyIn exceeded winnings, the result was a loss and the addition under section 115BB could not stand. The disallowance of Chapter VI-A deductions and house property interest was not finally decided because the assessee produced an updated return statement and challans for the first time before the Tribunal; the matter required factual verification, and the addition was to be deleted if tax had already been paid on the same amount.
Online gaming receipts were held to be taxable only on net winnings, not on a gross figure isolated from the gaming platform data; where BuyIn exceeded winnings, the result was a loss and the addition under section 115BB could not stand. The disallowance of Chapter VI-A deductions and house property interest was not finally decided because the assessee produced an updated return statement and challans for the first time before the Tribunal; the matter required factual verification, and the addition was to be deleted if tax had already been paid on the same amount.
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