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...
Penalty u/s 271(1)(C) - Disallowance of interest expenditure and letter of credit charges - difference of opinion between the AO as well as the assessee that the money that been utilized for the purpose of acquisition of the assets have been capitalized till the assets have been put to use - it cannot be said that assessee has furnished inaccurate particulars of its income
Penalty u/s 271(1)(C) - Disallowance of interest expenditure and letter of credit charges - difference of opinion between the AO as well as the assessee that the money that been utilized for the purpose of acquisition of the assets have been capitalized till the assets have been put to use - it cannot be said that assessee has furnished inaccurate particulars of its income
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