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 - adjustment in capital assets - given to the assessee to establish the industrial unit in backward regions of the Maharashtra State - from language of the Explanation 10 to section 43(1), it is manifest that it is attracted only when the object of the Scheme is to subsidize the cost of an asset and not otherwise.
Taxability of subsidy - adjustment in capital assets - given to the assessee to establish the industrial unit in backward regions of the Maharashtra State - from language of the Explanation 10 to section 43(1), it is manifest that it is attracted only when the object of the Scheme is to subsidize the cost of an asset and not otherwise.
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