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...
Nature of expenses - AO incorrectly applied matching principle for making disallowance, as he over looked the same line of business of the asessee where sales of vehicles are shown. In view of this, expenditure incurred by the assessee on setting up of a new line of assembly for manufacturing of commercial vehicle when assessee is already engaging in business of manufacturing commercial vehicle cannot be said to be capital expenditure. - Allowed as revenue expenditure - AT
Nature of expenses - AO incorrectly applied matching principle for making disallowance, as he over looked the same line of business of the asessee where sales of vehicles are shown. In view of this, expenditure incurred by the assessee on setting up of a new line of assembly for manufacturing of commercial vehicle when assessee is already engaging in business of manufacturing commercial vehicle cannot be said to be capital expenditure. - Allowed as revenue expenditure - AT
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