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...
Set off of capital loss - tax planning vs tax avoidance - shares were held by assessee for long period - transaction has not been doubted - sold at a price which was more than NAV value of shares as on date of sale of shares- allowable even if it is a case of tax planning within four corners of law and the same cannot be brushed aside.
Set off of capital loss - tax planning vs tax avoidance - shares were held by assessee for long period - transaction has not been doubted - sold at a price which was more than NAV value of shares as on date of sale of shares- allowable even if it is a case of tax planning within four corners of law and the same cannot be brushed aside.
Note: It is a system-generated summary and is for quick reference only.
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