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...
Revision u/s 263 - There was an error in the assessment order passed by the A.O. in not bringing to tax the interest income in the year under consideration under the head "income from other sources". Once, this interest income is brought to tax in A.Y. 2015-16, closing WIP for A.Y. 2015-16 will be increased to that extent and the income of the assessee chargeable to tax for A.Y. 2016-17 will be reduced consequently. - Revision order by CIT confirmed with modification - AT
Revision u/s 263 - There was an error in the assessment order passed by the A.O. in not bringing to tax the interest income in the year under consideration under the head "income from other sources". Once, this interest income is brought to tax in A.Y. 2015-16, closing WIP for A.Y. 2015-16 will be increased to that extent and the income of the assessee chargeable to tax for A.Y. 2016-17 will be reduced consequently. - Revision order by CIT confirmed with modification - AT
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