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...
Disallowance u/s 40(a)(ia) - TDS u/s 194C - the explanatory memorandum makes it clear that the scope of sec.194C was extended to cover Association of Persons from 1st June 2008 - It may be pertinent to note that the Trusts file their return of income under the category of “Association of Persons” only - assessees liable to deduct TDS
Disallowance u/s 40(a)(ia) - TDS u/s 194C - the explanatory memorandum makes it clear that the scope of sec.194C was extended to cover Association of Persons from 1st June 2008 - It may be pertinent to note that the Trusts file their return of income under the category of “Association of Persons” only - assessees liable to deduct TDS
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