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...
Approval u/s 80(G)(5) - for the purpose of deciding as to whether or not to grant approval u/s 80G, a CIT (Exemptions) has to only examine whether or not the conditions set out in Section 80G(5)(i) to (v) are satisfied - It cannot be open to the CIT(E) to reject on the ground that it is not conclusively established now that the assessee will be finally eligible in future for exemption u/ss 11, 12 and 10(23AA) or 10(23C)
Approval u/s 80(G)(5) - for the purpose of deciding as to whether or not to grant approval u/s 80G, a CIT (Exemptions) has to only examine whether or not the conditions set out in Section 80G(5)(i) to (v) are satisfied - It cannot be open to the CIT(E) to reject on the ground that it is not conclusively established now that the assessee will be finally eligible in future for exemption u/ss 11, 12 and 10(23AA) or 10(23C)
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