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...
Assessment u/s 153A - Addition for the pay-in from NBOT - AO was not justified as he cannot pick and choose the figures at his/her pleasure. Once it was decided to make the addition on the basis of gross transactions with NBOT then Ld. Assessing Officer was bound to consider both the figures of pay-in and pay-out. - AT
Assessment u/s 153A - Addition for the pay-in from NBOT - AO was not justified as he cannot pick and choose the figures at his/her pleasure. Once it was decided to make the addition on the basis of gross transactions with NBOT then Ld. Assessing Officer was bound to consider both the figures of pay-in and pay-out. - AT
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