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...
Profits of the SEZ manufacturing unit were excluded from book profit for AY 2011-12 because the withdrawal of the MAT exclusion operated prospectively from 1 April 2012. Disallowance under section 14A was confined to the amount of exempt income. Claims for deduction under section 10AA on alleged SEZ trading and manufacturing activities failed because the assessee did not produce credible evidence that the eligible operations were actually carried on, and exemption conditions had to be strictly proved. The Tribunal also upheld additions for cessation of trading liability under section 41(1) and unexplained sundry creditors under section 68 for want of proof of subsisting liabilities, identity, creditworthiness and genuineness.
Profits of the SEZ manufacturing unit were excluded from book profit for AY 2011-12 because the withdrawal of the MAT exclusion operated prospectively from 1 April 2012. Disallowance under section 14A was confined to the amount of exempt income. Claims for deduction under section 10AA on alleged SEZ trading and manufacturing activities failed because the assessee did not produce credible evidence that the eligible operations were actually carried on, and exemption conditions had to be strictly proved. The Tribunal also upheld additions for cessation of trading liability under section 41(1) and unexplained sundry creditors under section 68 for want of proof of subsisting liabilities, identity, creditworthiness and genuineness.
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