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...
Section 87A does not expressly bar rebate against tax payable on short-term capital gains from listed equity shares taxed at the special rate under section 111A. Applying a plain reading of both provisions and following the cited Tribunal precedent, rebate under section 87A is available in respect of such tax liability. Denial of the claimed rebate was therefore unsustainable, and the Assessing Officers were directed to grant it.
Section 87A does not expressly bar rebate against tax payable on short-term capital gains from listed equity shares taxed at the special rate under section 111A. Applying a plain reading of both provisions and following the cited Tribunal precedent, rebate under section 87A is available in respect of such tax liability. Denial of the claimed rebate was therefore unsustainable, and the Assessing Officers were directed to grant it.
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