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...
Section 11(6) bars depreciation as application of income for charitable purposes only where the acquisition cost of the relevant asset has already been claimed as application of income in the same or an earlier year. Where a charitable institution has not claimed capital expenditure on acquiring fixed assets as revenue application and claims only depreciation, the restriction does not create a double deduction. Depreciation on those fixed assets may therefore be treated as allowable application of income for the relevant assessment year.
Section 11(6) bars depreciation as application of income for charitable purposes only where the acquisition cost of the relevant asset has already been claimed as application of income in the same or an earlier year. Where a charitable institution has not claimed capital expenditure on acquiring fixed assets as revenue application and claims only depreciation, the restriction does not create a double deduction. Depreciation on those fixed assets may therefore be treated as allowable application of income for the relevant assessment year.
Note: It is a system-generated summary and is for quick reference only.
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