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 expenditure under section 57 remains deductible where borrowings retain a real nexus with assets generating income taxable under Income from Other Sources. Conversion of investments into sale proceeds and then fixed or term deposits does not, by itself, break that nexus. Deduction is not limited to interest income realised in the same year; arithmetical equivalence between expenditure and annual income is not required. An oral interest arrangement may establish an existing liability when supported by conduct and historical treatment. The creditor's accounting method and timing of taxability of corresponding interest are independently determined and cannot restrict the borrower's otherwise allowable deduction, subject to year-wise quantification, verification, and separate statutory disallowances.
Interest expenditure under section 57 remains deductible where borrowings retain a real nexus with assets generating income taxable under Income from Other Sources. Conversion of investments into sale proceeds and then fixed or term deposits does not, by itself, break that nexus. Deduction is not limited to interest income realised in the same year; arithmetical equivalence between expenditure and annual income is not required. An oral interest arrangement may establish an existing liability when supported by conduct and historical treatment. The creditor's accounting method and timing of taxability of corresponding interest are independently determined and cannot restrict the borrower's otherwise allowable deduction, subject to year-wise quantification, verification, and separate statutory disallowances.
Note: It is a system-generated summary and is for quick reference only.
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