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...
Depreciation by adopting the stamp value as per the provision of Section 50C - As per the scheme of the provision of Section 32 r.w.s 43(6) of the Act, which is a self contained scheme to compute the amount of deprecation allowable under the Act. According to our view, the reference to section 48 of the Act or the termful value of consideration are absent. Therefore, even otherwise, these two sections are not applicable in section 43(6) - AT
Depreciation by adopting the stamp value as per the provision of Section 50C - As per the scheme of the provision of Section 32 r.w.s 43(6) of the Act, which is a self contained scheme to compute the amount of deprecation allowable under the Act. According to our view, the reference to section 48 of the Act or the termful value of consideration are absent. Therefore, even otherwise, these two sections are not applicable in section 43(6) - AT
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