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...
Medical relief remains a distinct charitable purpose under section 12AB, and a hospital does not lose that character merely because it operates modern infrastructure, charges differential tariffs, serves paying patients or earns surplus, absent evidence of private enrichment, diversion of income, abandonment of objects, or use of funds for non-charitable purposes. For refusal or cancellation based on compliance with other laws, there must be an established breach determined by the competent authority; the income-tax authority cannot itself adjudicate alleged violations of the Maharashtra Public Trusts Act or the IPF Scheme. On that basis, retrospective cancellation and the consequential refusal of related approval were unsustainable.
Medical relief remains a distinct charitable purpose under section 12AB, and a hospital does not lose that character merely because it operates modern infrastructure, charges differential tariffs, serves paying patients or earns surplus, absent evidence of private enrichment, diversion of income, abandonment of objects, or use of funds for non-charitable purposes. For refusal or cancellation based on compliance with other laws, there must be an established breach determined by the competent authority; the income-tax authority cannot itself adjudicate alleged violations of the Maharashtra Public Trusts Act or the IPF Scheme. On that basis, retrospective cancellation and the consequential refusal of related approval were unsustainable.
Note: It is a system-generated summary and is for quick reference only.