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...
Addition of interest income under the head ‘income from other sources’ while computing tonnage tax u/s.115VI - The question whether the assessee had maintained separate books of accounts or not is irrelevant to decide the nature and head of income. Therefore, we are of the considered view that interest income earned by the assessee from deposits is not an income derived from shipping business and thus, the same is not entitled for tonnage tax scheme. - AT
Addition of interest income under the head ‘income from other sources’ while computing tonnage tax u/s.115VI - The question whether the assessee had maintained separate books of accounts or not is irrelevant to decide the nature and head of income. Therefore, we are of the considered view that interest income earned by the assessee from deposits is not an income derived from shipping business and thus, the same is not entitled for tonnage tax scheme. - AT
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