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...
Allowability of Interest Expenditure - The Tribunal noted a delay of 418 days in filing the quantum appeal by the assessee, which was condoned as the assessee pursued an alternative legal remedy before the Commissioner of Income Tax (Appeals) [CIT(A)]. - The main issue was the disallowance of interest on the grounds that borrowed funds were utilized for non-business purposes. The Tribunal found that the CIT(A) did not appropriately consider the remand report from the Assessing Officer (AO), which detailed the utilization of borrowed funds. Therefore, the Tribunal restored the quantum appeal to the file of the CIT(A) for re-adjudication in light of the AO's remand report. - AT
Allowability of Interest Expenditure - The Tribunal noted a delay of 418 days in filing the quantum appeal by the assessee, which was condoned as the assessee pursued an alternative legal remedy before the Commissioner of Income Tax (Appeals) [CIT(A)]. - The main issue was the disallowance of interest on the grounds that borrowed funds were utilized for non-business purposes. The Tribunal found that the CIT(A) did not appropriately consider the remand report from the Assessing Officer (AO), which detailed the utilization of borrowed funds. Therefore, the Tribunal restored the quantum appeal to the file of the CIT(A) for re-adjudication in light of the AO's remand report. - AT
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