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...
Disallowances as the overloading charges u/s 37 -whether this is nothing but a penalty as per provision of section 73 of the Indian Railway Act, 1989 - these payments were not in the nature of penalty for infringement of law and were purely in the nature of compensatory charges - expenses allowed - AT
Disallowances as the overloading charges u/s 37 -whether this is nothing but a penalty as per provision of section 73 of the Indian Railway Act, 1989 - these payments were not in the nature of penalty for infringement of law and were purely in the nature of compensatory charges - expenses allowed - AT
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