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 non-compete fee was treated as a consequential effect of an earlier appellate order, and the Revenue's objection was rejected because the Commissioner (Appeals) only directed implementation of that prior decision. Cost of production of TV serials and programmes was allowed as revenue expenditure on the basis of consistency, as the issue had already been decided in the assessee's favour for an earlier year and no contrary higher-court order was shown. Subscription revenue recognition was remanded because the dispute turned on verification of actual and real income, not merely the choice between mercantile and cash accounting; the Assessing Officer must examine the factual correctness of the estimated and actual figures.
Depreciation on non-compete fee was treated as a consequential effect of an earlier appellate order, and the Revenue's objection was rejected because the Commissioner (Appeals) only directed implementation of that prior decision. Cost of production of TV serials and programmes was allowed as revenue expenditure on the basis of consistency, as the issue had already been decided in the assessee's favour for an earlier year and no contrary higher-court order was shown. Subscription revenue recognition was remanded because the dispute turned on verification of actual and real income, not merely the choice between mercantile and cash accounting; the Assessing Officer must examine the factual correctness of the estimated and actual figures.
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