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...
Foreign exchange fluctuation - As we understand from the record, the gist of the method followed by the assessee is that, the assessee in Schedule IX claimed less deduction than claimable by adjusting the notional capital gain on Forex and corresponding deductions of the same amount while computing the net income of assessee for purpose of tax. In effect, both credit and debit are given and the tax liability is not materially impacted. Anyway, when the actual event has taken place, tax is stated to have been paid. The converse is that if the deduction is disallowed, the assessee would be called upon to pay tax on unrealised/notional capital gain; the treatment is as per the accounting standard, and the claim for deduction conforms with Section 43A of the Act. - HC
Foreign exchange fluctuation - As we understand from the record, the gist of the method followed by the assessee is that, the assessee in Schedule IX claimed less deduction than claimable by adjusting the notional capital gain on Forex and corresponding deductions of the same amount while computing the net income of assessee for purpose of tax. In effect, both credit and debit are given and the tax liability is not materially impacted. Anyway, when the actual event has taken place, tax is stated to have been paid. The converse is that if the deduction is disallowed, the assessee would be called upon to pay tax on unrealised/notional capital gain; the treatment is as per the accounting standard, and the claim for deduction conforms with Section 43A of the Act. - HC
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