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...
Value of the ‘Essar’ brand, trademarks and copyrights purported to have been settled by EIL to the assessee without any consideration, constituted taxable income as per section 56(1) - the CIT(A) had rightly concluded, that as the contribution of brand “Essar” as a gift by EIL to the corpus of the assessee trust did neither involve any profit element which could be brought within the meaning of “Income” under Sec. 2(24) of the Act, nor partook the nature of income, therefore, it could not be subjected to tax under the residuary head i.e “Other sources” u/s 56(1) of the Act, thus, uphold his view to the said extent. - AT
Value of the ‘Essar’ brand, trademarks and copyrights purported to have been settled by EIL to the assessee without any consideration, constituted taxable income as per section 56(1) - the CIT(A) had rightly concluded, that as the contribution of brand “Essar” as a gift by EIL to the corpus of the assessee trust did neither involve any profit element which could be brought within the meaning of “Income” under Sec. 2(24) of the Act, nor partook the nature of income, therefore, it could not be subjected to tax under the residuary head i.e “Other sources” u/s 56(1) of the Act, thus, uphold his view to the said extent. - AT
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