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...
Maintenance receipts collected under separate service agreements are distinguishable from rent where the letting and service arrangements are independently documented and the charges are separately identifiable. Such receipts may retain the character of business income, particularly where the services could be supplied by a third party, rather than forming part of income from house property. Interest on fresh borrowings used to replace earlier loans for the same let-out property may qualify for deduction under section 24(b), provided the borrowings relate to the property and the interest claim does not exceed the permitted basis. TDS credit requires factual verification that the corresponding income was offered to tax.
Maintenance receipts collected under separate service agreements are distinguishable from rent where the letting and service arrangements are independently documented and the charges are separately identifiable. Such receipts may retain the character of business income, particularly where the services could be supplied by a third party, rather than forming part of income from house property. Interest on fresh borrowings used to replace earlier loans for the same let-out property may qualify for deduction under section 24(b), provided the borrowings relate to the property and the interest claim does not exceed the permitted basis. TDS credit requires factual verification that the corresponding income was offered to tax.
Note: It is a system-generated summary and is for quick reference only.
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