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 on borrowings used to make interest-bearing unsecured advances is deductible against taxable interest income under section 57 where the nexus is established. The Assessing Officer's findings showed that the advances to private parties were funded through interest-bearing loans from banks and non-banking financial companies. As the borrowing cost was directly connected with earning the interest income assessed under income from other sources, the disallowance was deleted for the relevant assessment years.
Interest expenditure on borrowings used to make interest-bearing unsecured advances is deductible against taxable interest income under section 57 where the nexus is established. The Assessing Officer's findings showed that the advances to private parties were funded through interest-bearing loans from banks and non-banking financial companies. As the borrowing cost was directly connected with earning the interest income assessed under income from other sources, the disallowance was deleted for the relevant assessment years.
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