Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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Revision u/s 263 - income originally determined by the Assessing Officer at Nil remained the same even after giving effect to the order passed in revision - he shortcomings noticed by the ld. CIT in assessment order, which in his opinion made the order erroneous, are tax neutral - order of revision quashed.
Revision u/s 263 - income originally determined by the Assessing Officer at Nil remained the same even after giving effect to the order passed in revision - he shortcomings noticed by the ld. CIT in assessment order, which in his opinion made the order erroneous, are tax neutral - order of revision quashed.
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