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...
When on the same set of facts and circumstances of the case, renewal of approval under section 80G(5)(vi) has been granted for earlier years and there being no change in the facts and circumstances in the years for which renewal is sought for, there is no justification to reject the assessee's application for renewal of exemption certificate under section 80G(5)(vi) - AT
When on the same set of facts and circumstances of the case, renewal of approval under section 80G(5)(vi) has been granted for earlier years and there being no change in the facts and circumstances in the years for which renewal is sought for, there is no justification to reject the assessee's application for renewal of exemption certificate under section 80G(5)(vi) - AT
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