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...
Interest u/s 234B - scope of amendment in section 209 - entire payment received by the assessee from India was subject to TDS hence no interest is chargeable - The amendment brought into the act by the FA 2012 is applicable with effect from 01.04.2012 and is applicable from assessment year 2013 – 14 and prospective in nature
Interest u/s 234B - scope of amendment in section 209 - entire payment received by the assessee from India was subject to TDS hence no interest is chargeable - The amendment brought into the act by the FA 2012 is applicable with effect from 01.04.2012 and is applicable from assessment year 2013 – 14 and prospective in nature
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