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...
Deduction claimed under section 80-IB(10) - notify the industrial park of the petitioner under rule 18C of the Income-tax Rules, 1962 - The action of the CBDT instructing DIFF vide official memorandum dated March 1, 2012 to withdraw the approval suffers from the vice of arbitrariness and lacks jurisdiction. - CBDT directed to notify the petitioner's industrial park under rule 18C of the Income-tax Rules, 1962 in terms of the Industrial Park Scheme, 2002 in an expedited manner - HC
Deduction claimed under section 80-IB(10) - notify the industrial park of the petitioner under rule 18C of the Income-tax Rules, 1962 - The action of the CBDT instructing DIFF vide official memorandum dated March 1, 2012 to withdraw the approval suffers from the vice of arbitrariness and lacks jurisdiction. - CBDT directed to notify the petitioner's industrial park under rule 18C of the Income-tax Rules, 1962 in terms of the Industrial Park Scheme, 2002 in an expedited manner - HC
Note: It is a system-generated summary and is for quick reference only.