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...
Carry-forward of business losses requires the loss to be determined from a return filed under section 139(3) and quantified in assessment. Failure to file valid returns for intervening assessment years prevents determination and notification of the unabsorbed loss available for further carry-forward. Consequently, an earlier business loss cannot be set off in later years where intervening returns were not filed. The disallowance of the claimed set-off was upheld, and the appeals were dismissed because no substantial question of law arose.
Carry-forward of business losses requires the loss to be determined from a return filed under section 139(3) and quantified in assessment. Failure to file valid returns for intervening assessment years prevents determination and notification of the unabsorbed loss available for further carry-forward. Consequently, an earlier business loss cannot be set off in later years where intervening returns were not filed. The disallowance of the claimed set-off was upheld, and the appeals were dismissed because no substantial question of law arose.
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