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 deduction u/s 80P - Addition in respect of rental income earned and Income from sale of crackers - The Tribunal held that the deduction u/s 80P is available activity-wise and the rental income is not defined as per the section 80P, however assessee has shown such income separately and paid the taxes thereon. Hence, the question of disallowance u/s 80P does not arise, specifically when the assessee has never claimed deduction under section 80P of the Act in respect of the rental income and income sale of crackers.
Disallowance of deduction u/s 80P - Addition in respect of rental income earned and Income from sale of crackers - The Tribunal held that the deduction u/s 80P is available activity-wise and the rental income is not defined as per the section 80P, however assessee has shown such income separately and paid the taxes thereon. Hence, the question of disallowance u/s 80P does not arise, specifically when the assessee has never claimed deduction under section 80P of the Act in respect of the rental income and income sale of crackers.
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