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...
Additions towards amount of TDS deducted on interest - accrual of interest income but not received - Merely because the borrower has deposited TDS amount that itself will not fasten liability on the assessee to pay tax on the total interest income especially under the circumstances, when the other party has failed to repay the loan amount and interest thereupon and the litigation was going on. - AT
Additions towards amount of TDS deducted on interest - accrual of interest income but not received - Merely because the borrower has deposited TDS amount that itself will not fasten liability on the assessee to pay tax on the total interest income especially under the circumstances, when the other party has failed to repay the loan amount and interest thereupon and the litigation was going on. - AT
Note: It is a system-generated summary and is for quick reference only.
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