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...
TDS credit deducted by an employer cannot be denied to a salaried taxpayer solely because the employer failed to deposit the tax with the Revenue. The taxpayer remains entitled to credit where tax was deducted and cannot be made to bear the deductor's default. Denial through an intimation, consequential demand and recovery from refund was set aside to the extent of the disallowed TDS credit, with restoration of the recovered amount and applicable interest.
TDS credit deducted by an employer cannot be denied to a salaried taxpayer solely because the employer failed to deposit the tax with the Revenue. The taxpayer remains entitled to credit where tax was deducted and cannot be made to bear the deductor's default. Denial through an intimation, consequential demand and recovery from refund was set aside to the extent of the disallowed TDS credit, with restoration of the recovered amount and applicable interest.
Note: It is a system-generated summary and is for quick reference only.