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 to approved superannuation and gratuity funds are distinguished from ordinary annual contributions subject to prescribed ceilings. Payments made to bridge actuarially determined shortfalls and preserve a fund's ability to meet obligations are treated as deductible gap-funding contributions. While approval of a gratuity fund continues, assessment proceedings cannot re-examine compliance with its approval conditions. Employees' PF and ESI contributions may be disallowed only where payment misses a due date prescribed by the applicable regime. Where no such date exists, an audit-report date generated solely for e-filing purposes cannot establish delay. The disallowances concerning all three categories of contributions were deleted.
Actuarial deficit contributions to approved superannuation and gratuity funds are distinguished from ordinary annual contributions subject to prescribed ceilings. Payments made to bridge actuarially determined shortfalls and preserve a fund's ability to meet obligations are treated as deductible gap-funding contributions. While approval of a gratuity fund continues, assessment proceedings cannot re-examine compliance with its approval conditions. Employees' PF and ESI contributions may be disallowed only where payment misses a due date prescribed by the applicable regime. Where no such date exists, an audit-report date generated solely for e-filing purposes cannot establish delay. The disallowances concerning all three categories of contributions were deleted.
Note: It is a system-generated summary and is for quick reference only.
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