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...
Exemption u/s 11 - Once it is to be held that the assessee is a charitable institution and it is entitled for benefit u/s 11 and 12, then all other aspects of section 11(5) and 13(1)(d) etc are to be considered afresh. Somehow, it appears that the ld.AO failed to comprehend or concur with the higher appellate authorities about the status of the assessee being held as charitable institution, which is entitled for the benefit of section 11 and 12. - AT
Exemption u/s 11 - Once it is to be held that the assessee is a charitable institution and it is entitled for benefit u/s 11 and 12, then all other aspects of section 11(5) and 13(1)(d) etc are to be considered afresh. Somehow, it appears that the ld.AO failed to comprehend or concur with the higher appellate authorities about the status of the assessee being held as charitable institution, which is entitled for the benefit of section 11 and 12. - AT
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