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...
Addition u/s 56(2) - Allotment of shares - price less than the FMV - Merely by converting the share application money by allotting shares at a subsequent date cannot attract the provisions of section 56(2)(viia) as there is no change in the shareholding pattern subsequent to the allotment of shares by the subsidiary company. - AT
Addition u/s 56(2) - Allotment of shares - price less than the FMV - Merely by converting the share application money by allotting shares at a subsequent date cannot attract the provisions of section 56(2)(viia) as there is no change in the shareholding pattern subsequent to the allotment of shares by the subsidiary company. - AT
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