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...
Deduction of cost of funds from deposit income of a primary agricultural credit co-operative society requires fresh consideration in light of Totagars Co-operative Sale Society. The claim for proportionate administrative and other expenditure remains open for adjudication. The impugned intimation, assessment orders and consequential penalty orders for the relevant assessment years were quashed, and the matter was remanded to the competent authorities. The society may submit objections and reply to the notice issued under section 142(1).
Deduction of cost of funds from deposit income of a primary agricultural credit co-operative society requires fresh consideration in light of Totagars Co-operative Sale Society. The claim for proportionate administrative and other expenditure remains open for adjudication. The impugned intimation, assessment orders and consequential penalty orders for the relevant assessment years were quashed, and the matter was remanded to the competent authorities. The society may submit objections and reply to the notice issued under section 142(1).
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