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...
Domestic companies with turnover below the prescribed threshold are subject to the 25% corporate tax rate fixed by the Finance Act applicable to the relevant assessment year. An incorrect reference to section 115BA in the return does not justify applying the higher 30% rate where the company otherwise qualifies for the concessional rate. The applicable statutory rate must be applied to returned income, and the benefit is not denied solely because a revised return was not filed.
Domestic companies with turnover below the prescribed threshold are subject to the 25% corporate tax rate fixed by the Finance Act applicable to the relevant assessment year. An incorrect reference to section 115BA in the return does not justify applying the higher 30% rate where the company otherwise qualifies for the concessional rate. The applicable statutory rate must be applied to returned income, and the benefit is not denied solely because a revised return was not filed.
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