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...
Educational activities comprising banking-industry examinations, training programmes and related instruction qualify as charitable education where they equip banking personnel to perform their functions efficiently. Restricting benefits to a section of the public does not negate charitable character, and refusal of approval under a separate educational-institution regime does not determine exemption under charitable-trust provisions. Tax-free bond interest required no separate relief where exemption governed the institution's income computation. No depreciation disallowance arose because depreciation was not claimed. Accumulation of charitable income was permissible because the prescribed form identified definite purposes, including premises acquisition and renovation and development of educational, testing and data-centre facilities, rather than general objects.
Educational activities comprising banking-industry examinations, training programmes and related instruction qualify as charitable education where they equip banking personnel to perform their functions efficiently. Restricting benefits to a section of the public does not negate charitable character, and refusal of approval under a separate educational-institution regime does not determine exemption under charitable-trust provisions. Tax-free bond interest required no separate relief where exemption governed the institution's income computation. No depreciation disallowance arose because depreciation was not claimed. Accumulation of charitable income was permissible because the prescribed form identified definite purposes, including premises acquisition and renovation and development of educational, testing and data-centre facilities, rather than general objects.
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