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...
Depreciation on power plant at written down value method as against claimed by the appellant at straight line method - There is no bar under law that a captive undertaking is not eligible for deprecation under SLM basis - we note that in the past and subsequent years, the depreciation has been allowed under SLM basis and therefore, we see no rationale and justifiable basis for the CIT(A) to disturb the basis of allowing the depreciation under WDV instead of SLM basis as so claimed and allowed to the assessee over the years where there are no changes in the facts and circumstances of the case. - AT
Depreciation on power plant at written down value method as against claimed by the appellant at straight line method - There is no bar under law that a captive undertaking is not eligible for deprecation under SLM basis - we note that in the past and subsequent years, the depreciation has been allowed under SLM basis and therefore, we see no rationale and justifiable basis for the CIT(A) to disturb the basis of allowing the depreciation under WDV instead of SLM basis as so claimed and allowed to the assessee over the years where there are no changes in the facts and circumstances of the case. - AT
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