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...
TDS - u/s 194J and u/s 195 - payment by way of reimbursement to member companies, allowances paid to resident and non-resident personnel and payment to foreign agents - reimbursement of Indian Salary and benefits - Member employer company deducts tax at source under section 192 of the Act from the Indian salary of such employee as they continue to get their salary from his employer member companies. - CIT(A) rightly held that assessee not in default u/s 201(1) - AT
TDS - u/s 194J and u/s 195 - payment by way of reimbursement to member companies, allowances paid to resident and non-resident personnel and payment to foreign agents - reimbursement of Indian Salary and benefits - Member employer company deducts tax at source under section 192 of the Act from the Indian salary of such employee as they continue to get their salary from his employer member companies. - CIT(A) rightly held that assessee not in default u/s 201(1) - AT
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