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...
Foreign leave travel concession paid to employees is taxable as salary and is not exempt. An employer-bank must deduct tax at source on those payments; this obligation is separate from recovery of tax from employees. A stay or suspension of recovery proceedings against employees does not remove the deduction obligation, which applies again once any stay is vacated. Bank branches were treated as assessees in default where tax was neither deducted nor recovered during periods without an operative stay. Interest for non-deduction is mandatory and consequential, although relief may be sought for stayed periods or where an employee has paid self-assessment tax.
Foreign leave travel concession paid to employees is taxable as salary and is not exempt. An employer-bank must deduct tax at source on those payments; this obligation is separate from recovery of tax from employees. A stay or suspension of recovery proceedings against employees does not remove the deduction obligation, which applies again once any stay is vacated. Bank branches were treated as assessees in default where tax was neither deducted nor recovered during periods without an operative stay. Interest for non-deduction is mandatory and consequential, although relief may be sought for stayed periods or where an employee has paid self-assessment tax.
Note: It is a system-generated summary and is for quick reference only.
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