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...
Interest on term loan due from Joint Venture Companies - assessee claimed that the debt is already bad - the AO has noted that the assessee has not written off the loans in its books of account and the same figure is continuing even in subsequent assessment years. Moreover, the assessee itself treated the loan amount as “unsecured considered good” and interest due on the same - Additions confirmed - AT
Interest on term loan due from Joint Venture Companies - assessee claimed that the debt is already bad - the AO has noted that the assessee has not written off the loans in its books of account and the same figure is continuing even in subsequent assessment years. Moreover, the assessee itself treated the loan amount as “unsecured considered good” and interest due on the same - Additions confirmed - AT
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