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...
Disallowance in respect of gift and donation given to third parties - It is just like a donation or in the nature of gift, which cannot be allowed u/s 37. However, we make it clear that if the assessee produce necessary details to claim exemption u/s 80G of the Act, the same may be examined and exemption u/s 80G may be granted after verifying the relevant details from the receipt issued by the respective party. - AT
Disallowance in respect of gift and donation given to third parties - It is just like a donation or in the nature of gift, which cannot be allowed u/s 37. However, we make it clear that if the assessee produce necessary details to claim exemption u/s 80G of the Act, the same may be examined and exemption u/s 80G may be granted after verifying the relevant details from the receipt issued by the respective party. - AT
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