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...
Depreciation on goodwill arising from amalgamation remained allowable because the claim had consistently been accepted in the taxpayer's earlier assessment years and no material factual change was shown. The Revenue's reliance on a decision involving artificial and colourable creation of goodwill was distinguishable, with no comparable finding here. Deduction of employee stock option reimbursement expenditure was also sustained, as an earlier Tribunal ruling in the taxpayer's own matter had addressed objections on business purpose, capital character and tax deduction at source, and no distinguishing facts were produced. The Revenue's appeal was dismissed.
Depreciation on goodwill arising from amalgamation remained allowable because the claim had consistently been accepted in the taxpayer's earlier assessment years and no material factual change was shown. The Revenue's reliance on a decision involving artificial and colourable creation of goodwill was distinguishable, with no comparable finding here. Deduction of employee stock option reimbursement expenditure was also sustained, as an earlier Tribunal ruling in the taxpayer's own matter had addressed objections on business purpose, capital character and tax deduction at source, and no distinguishing facts were produced. The Revenue's appeal was dismissed.
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