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...
Interest u/s. 234C - advance tax - dividend has been received by the assessee only in third and fourth quarters of the financial year - the assessee had duly paid the advance tax on the said dividend income taxable u/s.115BBDA of the Act in the third and fourth quarters of the financial year. Hence, as per the old proviso to Section 234C (1) of the Act, there cannot be any levy of interest u/s.234C of the Act that could be fastened on the assessee for the first two quarters by apportioning dividend income for the whole year. - AT
Interest u/s. 234C - advance tax - dividend has been received by the assessee only in third and fourth quarters of the financial year - the assessee had duly paid the advance tax on the said dividend income taxable u/s.115BBDA of the Act in the third and fourth quarters of the financial year. Hence, as per the old proviso to Section 234C (1) of the Act, there cannot be any levy of interest u/s.234C of the Act that could be fastened on the assessee for the first two quarters by apportioning dividend income for the whole year. - AT
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