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...
Cessation of liability u/s 41(1) - conversion of the loan as well as the unpaid interest into share capital - when there was no writing off of liabilities and only the sub-head, under which, the liability was shown in the account books of the assessee was changed and it continued to remain liable to pay even after change of entries, there could be no cessation of liability - not taxable
Cessation of liability u/s 41(1) - conversion of the loan as well as the unpaid interest into share capital - when there was no writing off of liabilities and only the sub-head, under which, the liability was shown in the account books of the assessee was changed and it continued to remain liable to pay even after change of entries, there could be no cessation of liability - not taxable
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