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...
A statutory authority does not lose charitable character under the general public utility limb merely because, while pursuing its statutory objects, it earns receipts or undertakes activities with commercial attributes such as sale of plots. Applying the Supreme Court ruling in the assessee's own case, the court treated the issue as concluded on merits and held that cancellation of registration was not justified. The registration was therefore held to continue, and the challenge to cancellation under Section 12AA failed.
A statutory authority does not lose charitable character under the general public utility limb merely because, while pursuing its statutory objects, it earns receipts or undertakes activities with commercial attributes such as sale of plots. Applying the Supreme Court ruling in the assessee's own case, the court treated the issue as concluded on merits and held that cancellation of registration was not justified. The registration was therefore held to continue, and the challenge to cancellation under Section 12AA failed.
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