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 by CIT - Allowability of claim of deduction u/s. 80IB(10) - In case Revenue authorities are not satisfied with the contents of the completion certificate issued by Bhopal Municipal Corporation, they have option to file a writ before the Hon'ble Jurisdictional High Court but certainly they cannot deny the claim of deduction u/s. 80IB(10) of the Act which the assessee has claimed after obtaining all necessary certificate as well as the certificate from the Chartered Accountant and having fulfilled all the requirements of the provisions of section 80IB(10). - AT
Revision u/s 263 by CIT - Allowability of claim of deduction u/s. 80IB(10) - In case Revenue authorities are not satisfied with the contents of the completion certificate issued by Bhopal Municipal Corporation, they have option to file a writ before the Hon'ble Jurisdictional High Court but certainly they cannot deny the claim of deduction u/s. 80IB(10) of the Act which the assessee has claimed after obtaining all necessary certificate as well as the certificate from the Chartered Accountant and having fulfilled all the requirements of the provisions of section 80IB(10). - AT
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