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...
Addition u/s 36(1)(iii) - advanced interest bearing fund without charging any interest to its associate concerns - Whether it is commercially expedient or not for the Assessee cannot be decided by the Revenue authorities unless a decision taken by the Assessee can be held to be arbitrary or motivated, deliberately taken to defeat the purpose of the revenue
Addition u/s 36(1)(iii) - advanced interest bearing fund without charging any interest to its associate concerns - Whether it is commercially expedient or not for the Assessee cannot be decided by the Revenue authorities unless a decision taken by the Assessee can be held to be arbitrary or motivated, deliberately taken to defeat the purpose of the revenue
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