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...
Collection and recovery of equalisation levy - Clause 163 of the Bill provides for collection and recovery of equalisation levy by a person, being a resident and carrying on business or profession or a non-resident having a permanent establishment in India (assessee) by way of deduction from the amount paid or payable to the non-resident in respect of specified services. The amount of equalisation levy so deducted by the payer has to be paid to the credit of the Government by 7th day of the month following the month in which the equalisation levy is collected.
Collection and recovery of equalisation levy - Clause 163 of the Bill provides for collection and recovery of equalisation levy by a person, being a resident and carrying on business or profession or a non-resident having a permanent establishment in India (assessee) by way of deduction from the amount paid or payable to the non-resident in respect of specified services. The amount of equalisation levy so deducted by the payer has to be paid to the credit of the Government by 7th day of the month following the month in which the equalisation levy is collected.
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