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...
Taxability of unutilized accumulated funds u/s 11(2) as income u/s 11(3) - The CIT(A) upheld the Assessing Officer's decision, which was based on a Section 263 order from the DIT(E), regarding the taxability of these funds. However, the Tribunal, guided by a High Court order, restored the appeal to the CIT(A) for reconsideration, specifically within the framework of Sections 11(2) and 11(3) of the Act, after giving the assessee a fair opportunity to be heard. - AT
Taxability of unutilized accumulated funds u/s 11(2) as income u/s 11(3) - The CIT(A) upheld the Assessing Officer's decision, which was based on a Section 263 order from the DIT(E), regarding the taxability of these funds. However, the Tribunal, guided by a High Court order, restored the appeal to the CIT(A) for reconsideration, specifically within the framework of Sections 11(2) and 11(3) of the Act, after giving the assessee a fair opportunity to be heard. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4794
Join Channel
TaxTMI 
