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...
Delayed employer’s contributions to pension fund - provisions of section 43B of the Act would not be applicable to the assessee and even in the worse case scenario, the provisions of section 43B of the Act were to be applied, then the contribution would be considered as paid as the account was maintained by WBPDCL which is extended arm or instrumentality of the State Govt only. - AT
Delayed employer’s contributions to pension fund - provisions of section 43B of the Act would not be applicable to the assessee and even in the worse case scenario, the provisions of section 43B of the Act were to be applied, then the contribution would be considered as paid as the account was maintained by WBPDCL which is extended arm or instrumentality of the State Govt only. - AT
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