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...
TP adjustment - Inclusion of excise duty on the operating revenue for two comparables - By including excise duty in the case of two comparables by the ld. TPO, the operating profit has been artificially increased by the amount of excise duty and, therefore, the PLI computed by the learned TPO stands comparatively incorrect. We thus, find no fault with the computation of PLI after netting of excise duty done by the assessee for the purpose of benchmarking its sale and purchase transactions of raw material and goods with its AEs. - AT
TP adjustment - Inclusion of excise duty on the operating revenue for two comparables - By including excise duty in the case of two comparables by the ld. TPO, the operating profit has been artificially increased by the amount of excise duty and, therefore, the PLI computed by the learned TPO stands comparatively incorrect. We thus, find no fault with the computation of PLI after netting of excise duty done by the assessee for the purpose of benchmarking its sale and purchase transactions of raw material and goods with its AEs. - AT
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