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...
Fees paid to the Registrar of Companies for increasing share capital through shares issued to a holding company qualify for amortisation as preliminary expenditure. The provision covers expenditure incurred in connection with the issue of shares; it is not confined to expenses relating to a public subscription. The enumerated expenses are descriptive, and the comma after "issue" prevents a restrictive reading that would exclude Registrar fees. Accordingly, disallowance of the claimed amortisation was unsustainable, and amortisation of the share-capital issue fees was allowed.
Fees paid to the Registrar of Companies for increasing share capital through shares issued to a holding company qualify for amortisation as preliminary expenditure. The provision covers expenditure incurred in connection with the issue of shares; it is not confined to expenses relating to a public subscription. The enumerated expenses are descriptive, and the comma after "issue" prevents a restrictive reading that would exclude Registrar fees. Accordingly, disallowance of the claimed amortisation was unsustainable, and amortisation of the share-capital issue fees was allowed.
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