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...
Revision u/s 263 - commission paid to the MD to be disallowed - Even though it has not claimed 100% of the quantum of the value of assets due to the fact that the assets were acquired and utilized less than 180 days, it was eligible for only 50% of the rate of depreciation. Again, it cannot claim the additional depreciation u/s 32(1)(iia) - AT
Revision u/s 263 - commission paid to the MD to be disallowed - Even though it has not claimed 100% of the quantum of the value of assets due to the fact that the assets were acquired and utilized less than 180 days, it was eligible for only 50% of the rate of depreciation. Again, it cannot claim the additional depreciation u/s 32(1)(iia) - AT
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