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...
Employee-welfare payments to educational institutions and club expenditure were treated as business expenditure where incurred wholly and exclusively for business purposes. Enabling-facility costs were characterised as revenue expenditure because no capital asset was acquired. Receipts directly connected with setting up a plant were treated as capital receipts reducible from capital work-in-progress. Depreciation on business vehicles and temporary structures was allowed, while a challenge based on additional depreciation was treated as misconceived because the relief concerned consequential differential depreciation. Bad debts, advances and claims written off were allowable. Premium amortisation on foreign-exchange forward contracts used for hedging was non-speculative, not contingent or notional. Mineral-oil exploration and drilling survey expenditure qualified for deduction under the production-sharing contract framework.
Employee-welfare payments to educational institutions and club expenditure were treated as business expenditure where incurred wholly and exclusively for business purposes. Enabling-facility costs were characterised as revenue expenditure because no capital asset was acquired. Receipts directly connected with setting up a plant were treated as capital receipts reducible from capital work-in-progress. Depreciation on business vehicles and temporary structures was allowed, while a challenge based on additional depreciation was treated as misconceived because the relief concerned consequential differential depreciation. Bad debts, advances and claims written off were allowable. Premium amortisation on foreign-exchange forward contracts used for hedging was non-speculative, not contingent or notional. Mineral-oil exploration and drilling survey expenditure qualified for deduction under the production-sharing contract framework.
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