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...
Interest on bank fixed deposits held in a trust's name constitutes the trust's income, even where the funds are intended for Self-Help Groups. Corpus exemption requires a specific written direction from the donor; correspondence allowing distribution of refunded funds did not direct that deposit interest form part of the corpus. A later obligation to allocate funds to Self-Help Groups is application of income, not diversion at source. The trust cannot claim tax deducted at source credit while excluding the interest from revenue receipts. The interest was taxable as revenue income, and its addition was affirmed.
Interest on bank fixed deposits held in a trust's name constitutes the trust's income, even where the funds are intended for Self-Help Groups. Corpus exemption requires a specific written direction from the donor; correspondence allowing distribution of refunded funds did not direct that deposit interest form part of the corpus. A later obligation to allocate funds to Self-Help Groups is application of income, not diversion at source. The trust cannot claim tax deducted at source credit while excluding the interest from revenue receipts. The interest was taxable as revenue income, and its addition was affirmed.
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