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...
Scholarships paid in India to Indian students for foreign education are treated as domestic application of income where the funds are disbursed in India in Indian currency to the students or their guardians and no payment is made to a foreign university. Subsequent use abroad does not convert the payment into application outside India, so denial of charitable registration on that basis is unsustainable; the text also notes that approval for charitable donation purposes follows once registration is granted and no independent objection remains.
Scholarships paid in India to Indian students for foreign education are treated as domestic application of income where the funds are disbursed in India in Indian currency to the students or their guardians and no payment is made to a foreign university. Subsequent use abroad does not convert the payment into application outside India, so denial of charitable registration on that basis is unsustainable; the text also notes that approval for charitable donation purposes follows once registration is granted and no independent objection remains.
Note: It is a system-generated summary and is for quick reference only.