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...
Slump sale - if the sale consideration of the undertaking as a whole has been fixed without specifying any specific value to any asset and its includes tangible as well as intangible asset - further the assessee has also agreed for not carrying on the similar business for 10 years - it is a case of “slump sale” of undertaking as a going concern and not the sale of depreciable assets within the meaning of Section 50
Slump sale - if the sale consideration of the undertaking as a whole has been fixed without specifying any specific value to any asset and its includes tangible as well as intangible asset - further the assessee has also agreed for not carrying on the similar business for 10 years - it is a case of “slump sale” of undertaking as a going concern and not the sale of depreciable assets within the meaning of Section 50
Note: It is a system-generated summary and is for quick reference only.
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