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...
Deemed dividend u/s 2(22)(e) - amount received by the assessee from his father - family settlement - transfer of money from father to son is nothing unusual - The observation of AO that the agreement is artificially created for the purpose of withdrawing money by the assessee from the accumulated profits of MEL is not maintainable.
Deemed dividend u/s 2(22)(e) - amount received by the assessee from his father - family settlement - transfer of money from father to son is nothing unusual - The observation of AO that the agreement is artificially created for the purpose of withdrawing money by the assessee from the accumulated profits of MEL is not maintainable.
Note: It is a system-generated summary and is for quick reference only.
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