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...
Subletting charges paid to MIDC as a mandatory condition for subletting leasehold property are treated as an integral cost of earning rental income. Taxable income from house property is therefore computed on net rental income after reducing those charges. The standard deduction available for house property income under section 24(a) does not prevent deduction of such pre-receipt expenditure, because the charges are necessary to commercially exploit the leasehold property through subletting. The disallowance of the charges was deleted and the deduction was allowed.
Subletting charges paid to MIDC as a mandatory condition for subletting leasehold property are treated as an integral cost of earning rental income. Taxable income from house property is therefore computed on net rental income after reducing those charges. The standard deduction available for house property income under section 24(a) does not prevent deduction of such pre-receipt expenditure, because the charges are necessary to commercially exploit the leasehold property through subletting. The disallowance of the charges was deleted and the deduction was allowed.
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