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...
Land acquired in an individual's name for the appellant did not establish a real estate agent relationship, because the records showed the acquisition was on the appellant's behalf and no service was rendered to the housing society; the demand on that category was set aside. For works contract valuation, Rule 2A(ii) applies only when value cannot be determined under Rule 2A(i); the Revenue could not selectively accept some invoices and reject others without first determining the service portion, so the differential demand failed. The uncontested goods transport agency tax, already paid during audit, was confirmed.
Land acquired in an individual's name for the appellant did not establish a real estate agent relationship, because the records showed the acquisition was on the appellant's behalf and no service was rendered to the housing society; the demand on that category was set aside. For works contract valuation, Rule 2A(ii) applies only when value cannot be determined under Rule 2A(i); the Revenue could not selectively accept some invoices and reject others without first determining the service portion, so the differential demand failed. The uncontested goods transport agency tax, already paid during audit, was confirmed.
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