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...
Where the Department's remand report accepted the assessee's explanation on notional interest, ad hoc disallowance of expenses, and addition of trade payables, there was no basis to sustain any addition. The ITAT found no reason to interfere with the CIT(A)'s deletion of the additions relating to notional interest on interest-free advances to a subsidiary, power, fuel, administrative and repair ? Wait no. Use English. and trade payables, and upheld the deletion of all disputed adjustments.
Where the Department's remand report accepted the assessee's explanation on notional interest, ad hoc disallowance of expenses, and addition of trade payables, there was no basis to sustain any addition. The ITAT found no reason to interfere with the CIT(A)'s deletion of the additions relating to notional interest on interest-free advances to a subsidiary, power, fuel, administrative and repair ? Wait no. Use English. and trade payables, and upheld the deletion of all disputed adjustments.
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