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...
Denial of exemption u/s 10(23C)(vi) - CIT(E) observed the huge surplus which indicates that the activities are conducted with the motive of profit. - even if for any year the taxpayer is found to be existing solely for educational purposes and not for purposes of profit, the assessee still has to continuously satisfy this pivotal condition each and every year. - Since the assessee has been found to be not ‘existing’ solely for the purposes of education, denial of exemption u/s 10(23C)(vi) of the Act is upheld. - AT
Denial of exemption u/s 10(23C)(vi) - CIT(E) observed the huge surplus which indicates that the activities are conducted with the motive of profit. - even if for any year the taxpayer is found to be existing solely for educational purposes and not for purposes of profit, the assessee still has to continuously satisfy this pivotal condition each and every year. - Since the assessee has been found to be not ‘existing’ solely for the purposes of education, denial of exemption u/s 10(23C)(vi) of the Act is upheld. - AT
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