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...
CBDT authorises the Director General of Income-tax (Systems), Delhi to upload AEOI information received under agreements referred to in sections 90 and 90A into the Annual Information Statement in Form 26AS. The order covers information for the periods 1 January 2022 to 31 December 2022, 1 January 2023 to 31 December 2023, and 1 January 2024 to 31 December 2024 if already in possession within 90 days of the order, and for 1 January 2025 to 31 December 2025 if received within 90 days from the end of the month of receipt. The Director General is also required to specify the procedures, formats and standards for such uploading.
CBDT authorises the Director General of Income-tax (Systems), Delhi to upload AEOI information received under agreements referred to in sections 90 and 90A into the Annual Information Statement in Form 26AS. The order covers information for the periods 1 January 2022 to 31 December 2022, 1 January 2023 to 31 December 2023, and 1 January 2024 to 31 December 2024 if already in possession within 90 days of the order, and for 1 January 2025 to 31 December 2025 if received within 90 days from the end of the month of receipt. The Director General is also required to specify the procedures, formats and standards for such uploading.
Note: It is a system-generated summary and is for quick reference only.