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 interest expenses - assessee has not charged any interest in respect of advance given to the wife of the one of the key personnel of the company - In view of the huge funds available with the assessee without any interest liability, we find that the issue is squarely covered in favour of assessee. - AT
Disallowance of interest expenses - assessee has not charged any interest in respect of advance given to the wife of the one of the key personnel of the company - In view of the huge funds available with the assessee without any interest liability, we find that the issue is squarely covered in favour of assessee. - AT
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