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...
Higher depreciation for computer peripherals is supported where printers, scanners, modems and routers function as necessary accessories of a computer system, are included in the computer block, and consistent prior treatment is accepted. Production expenditure for TV news, serials and programmes is treated as revenue expenditure when it arises from regular business operations; possible repeat-telecast value alone does not establish an enduring capital benefit. A film software library is treated as an intangible business or commercial right eligible for depreciation at 25%, particularly where the same treatment was followed earlier. Depreciation on a proportionate non-compete fee allocated on demerger is sustained where the demerged entity received corresponding allowance and no contrary facts or decision exist.
Higher depreciation for computer peripherals is supported where printers, scanners, modems and routers function as necessary accessories of a computer system, are included in the computer block, and consistent prior treatment is accepted. Production expenditure for TV news, serials and programmes is treated as revenue expenditure when it arises from regular business operations; possible repeat-telecast value alone does not establish an enduring capital benefit. A film software library is treated as an intangible business or commercial right eligible for depreciation at 25%, particularly where the same treatment was followed earlier. Depreciation on a proportionate non-compete fee allocated on demerger is sustained where the demerged entity received corresponding allowance and no contrary facts or decision exist.
Note: It is a system-generated summary and is for quick reference only.
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