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...
Digital advertising and sales-promotion expenditure on media space, SMS broadcasts, search-engine optimisation, campaign content, marketing videos and social-media strategy is revenue expenditure where it comprises recurring promotional measures, creates no business asset and only improves product promotion through a digital platform. The enduring-benefit test does not make such expenditure capital without an asset or capital-field advantage. Payments for website and mobile-app search services are likewise revenue expenditure where they improve product searches, correct search terms and facilitate sales without creating a capital asset or enduring capital advantage. Disallowances of both categories were deleted; the Revenue's appeals failed and supportive cross-objections became infructuous.
Digital advertising and sales-promotion expenditure on media space, SMS broadcasts, search-engine optimisation, campaign content, marketing videos and social-media strategy is revenue expenditure where it comprises recurring promotional measures, creates no business asset and only improves product promotion through a digital platform. The enduring-benefit test does not make such expenditure capital without an asset or capital-field advantage. Payments for website and mobile-app search services are likewise revenue expenditure where they improve product searches, correct search terms and facilitate sales without creating a capital asset or enduring capital advantage. Disallowances of both categories were deleted; the Revenue's appeals failed and supportive cross-objections became infructuous.
Note: It is a system-generated summary and is for quick reference only.
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