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...
Unclaimed student caution money held by a charitable trust was treated as a refundable security deposit and not as a trading liability or an amount on which deduction had earlier been allowed. As the amount was neither forfeited nor written back and the trust continued to recognise it in its books, there was no remission or cessation of liability; mere lapse of time did not extinguish the debt, so the addition under section 41(1) failed. On interest paid to specified persons, the Tribunal upheld the finding that the rate was excessive, and the surviving disallowance under section 40A(2) was sustained.
Unclaimed student caution money held by a charitable trust was treated as a refundable security deposit and not as a trading liability or an amount on which deduction had earlier been allowed. As the amount was neither forfeited nor written back and the trust continued to recognise it in its books, there was no remission or cessation of liability; mere lapse of time did not extinguish the debt, so the addition under section 41(1) failed. On interest paid to specified persons, the Tribunal upheld the finding that the rate was excessive, and the surviving disallowance under section 40A(2) was sustained.
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