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 - The civil contract awarded to a firm in which the managing trustee of the trust is proprietor is tantamount to services as defined u/s. 13(2)(c) - Since, payment made in pursuant to services rendered by the interested persons is not in excess of consideration paid for relevant work, it cannot be held that there is a direct or indirect benefit to the interested persons as referred to u/s. 13(2) of the Act and violation of provisions of section 13(1)(c) of the Act. - AT
Exemption u/s. 11 - The civil contract awarded to a firm in which the managing trustee of the trust is proprietor is tantamount to services as defined u/s. 13(2)(c) - Since, payment made in pursuant to services rendered by the interested persons is not in excess of consideration paid for relevant work, it cannot be held that there is a direct or indirect benefit to the interested persons as referred to u/s. 13(2) of the Act and violation of provisions of section 13(1)(c) of the Act. - AT
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