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...
Exemption u/s 11 - seeking benefit on the ground of mutuality in case of denial of benefit of section 11 by invoking section 13 - the assessee has clearly gave the details to the Assessing Officer that it has dealt only with the 140 non-members and details of their subscriptions, it shows that the assessee kept the record of dealing with the non-members. Therefore, we are inclined to remit this issue back to the file of Assessing Officer to evaluate the allowability of benefit under mutuality concept to the assessee.- AT
Exemption u/s 11 - seeking benefit on the ground of mutuality in case of denial of benefit of section 11 by invoking section 13 - the assessee has clearly gave the details to the Assessing Officer that it has dealt only with the 140 non-members and details of their subscriptions, it shows that the assessee kept the record of dealing with the non-members. Therefore, we are inclined to remit this issue back to the file of Assessing Officer to evaluate the allowability of benefit under mutuality concept to the assessee.- AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
