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...
TDS on the ‘stake money’ paid to the horse owners on winning of races - Circular No. 240 dated 17.05.1978, clarified that tax was not required to be deducted u/s 194BB with respect to income by way of ‘stake money’ as the same is not regarded as winning from horse races - neither liable to TDS u/s 194B nor u/s 194BB and thus, assessee should not be treated as an ‘assessee in default’ u/s 201(1)
TDS on the ‘stake money’ paid to the horse owners on winning of races - Circular No. 240 dated 17.05.1978, clarified that tax was not required to be deducted u/s 194BB with respect to income by way of ‘stake money’ as the same is not regarded as winning from horse races - neither liable to TDS u/s 194B nor u/s 194BB and thus, assessee should not be treated as an ‘assessee in default’ u/s 201(1)
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