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...
Disallowance on account of expenses incurred through sub-contractors - bogus expenditure - these companies are merely paper companies, having complied with proper paper work, but not possessing necessary expertise to render technical services to the assessee - Even if TDS was deducted, expenditure cannot be allowed. - AT
Disallowance on account of expenses incurred through sub-contractors - bogus expenditure - these companies are merely paper companies, having complied with proper paper work, but not possessing necessary expertise to render technical services to the assessee - Even if TDS was deducted, expenditure cannot be allowed. - AT
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