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...
Deduction u/s 80P - Failure to file Tax Audit Report - assessee did not submit the audit report as per section 63 of the Karnataka State Co-operative Society Act, 1959 - The omission or wrong statement has not been defined in the Income Tax Act. The assessee was well aware about the business carried on by it and is also aware about the filing of return of income and he has made provision for income tax in its books for preceding assessment years. The assessee will not get the benefit of extended due date for filling return of income as notified - AT
Deduction u/s 80P - Failure to file Tax Audit Report - assessee did not submit the audit report as per section 63 of the Karnataka State Co-operative Society Act, 1959 - The omission or wrong statement has not been defined in the Income Tax Act. The assessee was well aware about the business carried on by it and is also aware about the filing of return of income and he has made provision for income tax in its books for preceding assessment years. The assessee will not get the benefit of extended due date for filling return of income as notified - AT
Note: It is a system-generated summary and is for quick reference only.