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...
Interest expenditure may be deducted against dividend income only to the extent that borrowed funds have a direct nexus with investments generating that income; the extent of such nexus is a factual determination and the balance interest cannot be deducted without supporting evidence. No notional interest is taxable on refundable security deposits for employee residential premises where the deposits serve business purposes and generate no actual income. The High Court also rejected the Revenue's challenges concerning deduction for a new industrial undertaking in existing factory premises and interest and trial-run overheads relating to new machinery, following prior decisions. Questions on closing-stock valuation, including excise-duty treatment, were answered under an earlier High Court ruling.
Interest expenditure may be deducted against dividend income only to the extent that borrowed funds have a direct nexus with investments generating that income; the extent of such nexus is a factual determination and the balance interest cannot be deducted without supporting evidence. No notional interest is taxable on refundable security deposits for employee residential premises where the deposits serve business purposes and generate no actual income. The High Court also rejected the Revenue's challenges concerning deduction for a new industrial undertaking in existing factory premises and interest and trial-run overheads relating to new machinery, following prior decisions. Questions on closing-stock valuation, including excise-duty treatment, were answered under an earlier High Court ruling.
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