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 10(23C)(vi) - scope of the term "Education" - no specific definition for "education" under the Income Tax Act of 1961 - assisting Banking Institutions in the matters such as appraisal programmes, conducting morale and productivity studies etc., also fall within the category of education. It is not in dispute that the assessee is a Staff Training College for Bank employees. Therefore, in our considered view, assessee must be construed as an Educational Institution because the main object is to train the Bank Officials. - HC
Exemption u/s 10(23C)(vi) - scope of the term "Education" - no specific definition for "education" under the Income Tax Act of 1961 - assisting Banking Institutions in the matters such as appraisal programmes, conducting morale and productivity studies etc., also fall within the category of education. It is not in dispute that the assessee is a Staff Training College for Bank employees. Therefore, in our considered view, assessee must be construed as an Educational Institution because the main object is to train the Bank Officials. - HC
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