Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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Section 54EC exemption for long-term capital gains may apply where specified bonds are purchased within six months of transfer across two financial years. For Assessment Year 2013-14, the investment ceiling operated independently for each financial year when the six-month period overlapped them, rather than as a single transaction-wide cap. The later amendment imposing an aggregate cap for the year of transfer and the succeeding financial year did not apply. Accordingly, restricting the exemption to one financial year's ceiling was set aside and the disallowance was deleted.
Section 54EC exemption for long-term capital gains may apply where specified bonds are purchased within six months of transfer across two financial years. For Assessment Year 2013-14, the investment ceiling operated independently for each financial year when the six-month period overlapped them, rather than as a single transaction-wide cap. The later amendment imposing an aggregate cap for the year of transfer and the succeeding financial year did not apply. Accordingly, restricting the exemption to one financial year's ceiling was set aside and the disallowance was deleted.
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