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...
Actuarial deficit contributions made to an approved superannuation fund to align fund assets with actuarial liabilities are distinguished from ordinary annual or initial contributions. Because their purpose is to remedy an actuarial shortfall, they are not subject to the Rule 87 ceiling on annual contributions, preserving the fund's solvency. Similarly, contributions bridging actuarial liability and available assets in an approved gratuity fund are not ordinary annual contributions subject to the Rule 103 ceiling. Unless approval is formally withdrawn, the assessing authority must accept the fund's approved status and cannot, during assessment, question compliance with the Rules to restrict the deduction.
Actuarial deficit contributions made to an approved superannuation fund to align fund assets with actuarial liabilities are distinguished from ordinary annual or initial contributions. Because their purpose is to remedy an actuarial shortfall, they are not subject to the Rule 87 ceiling on annual contributions, preserving the fund's solvency. Similarly, contributions bridging actuarial liability and available assets in an approved gratuity fund are not ordinary annual contributions subject to the Rule 103 ceiling. Unless approval is formally withdrawn, the assessing authority must accept the fund's approved status and cannot, during assessment, question compliance with the Rules to restrict the deduction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
