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 of travelling expenses - assessee was in the business of real estate and could not substantiate before the lower authorities with any relevant evidences that foreign travel expenses were incurred for the purpose of business of the assessee - additions confirmed.
Disallowance of travelling expenses - assessee was in the business of real estate and could not substantiate before the lower authorities with any relevant evidences that foreign travel expenses were incurred for the purpose of business of the assessee - additions confirmed.
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