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...
Disallowance of deduction u/s 80IB(11A) - On perusal of tax audit report, the nature of the business activity of the assessee has been shown as cold storage services and in financial statements also as well as as per the orders of lower authorities, Form 10CCB also does not reflect that the assessee is carrying or engaged in the business of handling, storage and transportation of food grains and also not taking of any business of processing and packaging of goods or vegetables vide sl. Nos. 24(b) and 24(c) respectively. No doubt, the assessee is operating cold storage, but, other ingredients for eligibility of deduction is not satisfied. - AT
Disallowance of deduction u/s 80IB(11A) - On perusal of tax audit report, the nature of the business activity of the assessee has been shown as cold storage services and in financial statements also as well as as per the orders of lower authorities, Form 10CCB also does not reflect that the assessee is carrying or engaged in the business of handling, storage and transportation of food grains and also not taking of any business of processing and packaging of goods or vegetables vide sl. Nos. 24(b) and 24(c) respectively. No doubt, the assessee is operating cold storage, but, other ingredients for eligibility of deduction is not satisfied. - AT
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