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...
Valuation - removal of goods on transfer of right to use - Notwithstanding the clearances being shown as stock-transfer to Head office, this was only a routing on paper only, however in actuality the impugned servers were delivered in the same condition as they were removed, to the theatre owners. Possibly, appellant had followed such a tedious billing route for accounting reasons - issue of valuation decided against the assessee - AT
Valuation - removal of goods on transfer of right to use - Notwithstanding the clearances being shown as stock-transfer to Head office, this was only a routing on paper only, however in actuality the impugned servers were delivered in the same condition as they were removed, to the theatre owners. Possibly, appellant had followed such a tedious billing route for accounting reasons - issue of valuation decided against the assessee - AT
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