Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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Disallowance of claim of ‘surrender right fee’ - allowable business expenditure or not? - the assessee was not able to get necessary approvals and clause 3.4 provided that upon termination of the agreement as a result of failure to receipt approvals all advances granted by buyer to seller have to be returned in 30 days. - The amount to settle for an agreement allowed as expenditure - AT
Disallowance of claim of ‘surrender right fee’ - allowable business expenditure or not? - the assessee was not able to get necessary approvals and clause 3.4 provided that upon termination of the agreement as a result of failure to receipt approvals all advances granted by buyer to seller have to be returned in 30 days. - The amount to settle for an agreement allowed as expenditure - AT
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