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 of interest u/s. 36(1)(iii) - loan borrowed for the purpose of settling outgoing partners’ capital account - The settlement of capital account of outgoing partners becomes debt of partnership firm and discharge of said debt out of borrowed funds assumes the character of loans/funds borrowed for the purpose of business of the assessee. - interest paid on borrowed capital account is allowable deduction u/s. 36(1)(iii) of the Act. - AT
Disallowance of interest u/s. 36(1)(iii) - loan borrowed for the purpose of settling outgoing partners’ capital account - The settlement of capital account of outgoing partners becomes debt of partnership firm and discharge of said debt out of borrowed funds assumes the character of loans/funds borrowed for the purpose of business of the assessee. - interest paid on borrowed capital account is allowable deduction u/s. 36(1)(iii) of the Act. - AT
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