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...
Section 80-IE deduction remains available where an industrial undertaking is not formed by splitting up or reconstruction of an existing business and previously used plant and machinery does not exceed the statutory limit. Eligible profits cannot be recomputed through notional allocation of related-party expenses unless material establishes an arrangement, beyond close connection alone, designed to generate more than ordinary profits. Excise-duty incentives intended to promote industrial development and employment are capital receipts, excluded both from taxable income and from eligible profits for the deduction. Working-partner remuneration cannot be disallowed twice where it has already been added back in the revised return.
Section 80-IE deduction remains available where an industrial undertaking is not formed by splitting up or reconstruction of an existing business and previously used plant and machinery does not exceed the statutory limit. Eligible profits cannot be recomputed through notional allocation of related-party expenses unless material establishes an arrangement, beyond close connection alone, designed to generate more than ordinary profits. Excise-duty incentives intended to promote industrial development and employment are capital receipts, excluded both from taxable income and from eligible profits for the deduction. Working-partner remuneration cannot be disallowed twice where it has already been added back in the revised return.
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