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...
Taxability of subsidy - revenue of capital - subsidy to establish the industrial unit in backward regions of the Maharashtra State is in nature of capital receipt - quantification in the form of rebate on the Excise duty does not alter the nature of subsidy from capital to a revenue receipt - insertion of sub-clause (xviii) in Section 2(24) is prospective and effective from AY 2016-17
Taxability of subsidy - revenue of capital - subsidy to establish the industrial unit in backward regions of the Maharashtra State is in nature of capital receipt - quantification in the form of rebate on the Excise duty does not alter the nature of subsidy from capital to a revenue receipt - insertion of sub-clause (xviii) in Section 2(24) is prospective and effective from AY 2016-17
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