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...
Ind AS book entries do not independently determine taxable income, which must be computed under the Act and applicable ICDS. Notional security-deposit amortisation and deferred royalty recognition did not create taxable income where no real accrual occurred or consideration had already been taxed; related additions were deleted. EPCG duty benefits were governed by the statutory actual-cost treatment rather than Ind AS grant presentation, and the addition was deleted. ICDS IX capitalisation differences did not establish double deduction without evidence. Transferable development-right cost, leave provision and gift expenditure required verification or fresh adjudication. Weighted R&D deduction remained available where the facility was approved, despite the prescribed authority not issuing Form 3CL.
Ind AS book entries do not independently determine taxable income, which must be computed under the Act and applicable ICDS. Notional security-deposit amortisation and deferred royalty recognition did not create taxable income where no real accrual occurred or consideration had already been taxed; related additions were deleted. EPCG duty benefits were governed by the statutory actual-cost treatment rather than Ind AS grant presentation, and the addition was deleted. ICDS IX capitalisation differences did not establish double deduction without evidence. Transferable development-right cost, leave provision and gift expenditure required verification or fresh adjudication. Weighted R&D deduction remained available where the facility was approved, despite the prescribed authority not issuing Form 3CL.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
