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 11 - Accumulation of income - The money referred in Clause (b) (ii) is one accumulated or set apart. Meaning thereby that even if 85% of the income referred in clause (a) or sub-clause (b) of sub section 1 of Section 11 read with the explanation 2 to that sub section (1) is applied to charitable or religious purposes then to claim exemption on the whole of the income, the accumulated or set apart income has to be deposited or invested in the investments identified in sub section (5) of section 11. - AT
Exemption u/s 11 - Accumulation of income - The money referred in Clause (b) (ii) is one accumulated or set apart. Meaning thereby that even if 85% of the income referred in clause (a) or sub-clause (b) of sub section 1 of Section 11 read with the explanation 2 to that sub section (1) is applied to charitable or religious purposes then to claim exemption on the whole of the income, the accumulated or set apart income has to be deposited or invested in the investments identified in sub section (5) of section 11. - AT
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