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...
Unexplained investment - Tax value of certain assets received by it free of cost under Section 28(iv) - Therefore, the addition u/s. 69 of the Act cannot be sustained. - The entire value of assets has to be regarded as an addition made u/s. 28(1)(iv) of the Act, as was done by the AO - However the same would be eligible for deduction u/s 10A
Unexplained investment - Tax value of certain assets received by it free of cost under Section 28(iv) - Therefore, the addition u/s. 69 of the Act cannot be sustained. - The entire value of assets has to be regarded as an addition made u/s. 28(1)(iv) of the Act, as was done by the AO - However the same would be eligible for deduction u/s 10A
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