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...
Exemption u/s 10(26AAA) - Sikkimese - the assessee though is not a Sikkimese and is name is not appearing in the Register of Sikkim but as per the residential certificate issued by the District Collector, East District, Gangtok, he is found to be domiciled in the state of Sikkim on or before 26th April, 1975 and, therefore, assessee is well covered by the decision of the Hon’ble Supreme Court and thus, is entitled to exemption u/s 10(26AAA) - AT
Exemption u/s 10(26AAA) - Sikkimese - the assessee though is not a Sikkimese and is name is not appearing in the Register of Sikkim but as per the residential certificate issued by the District Collector, East District, Gangtok, he is found to be domiciled in the state of Sikkim on or before 26th April, 1975 and, therefore, assessee is well covered by the decision of the Hon’ble Supreme Court and thus, is entitled to exemption u/s 10(26AAA) - AT
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