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...
Allowable expenditure versus Application of Income (Repayment of loan) - Payment made to the Marketing Board - progressive payments given to the Haryana State Agricultural Marketing Board from the year 2006 onwards till the year 2009 - payment of liability of old loan - The High court found that the payment made was for the achievement of the objectives prescribed under the Punjab Agricultural Produce Markets Act, 1961. Therefore, it should not be considered as a repayment of a loan, and the disallowance made was based on incorrect reasoning.
Allowable expenditure versus Application of Income (Repayment of loan) - Payment made to the Marketing Board - progressive payments given to the Haryana State Agricultural Marketing Board from the year 2006 onwards till the year 2009 - payment of liability of old loan - The High court found that the payment made was for the achievement of the objectives prescribed under the Punjab Agricultural Produce Markets Act, 1961. Therefore, it should not be considered as a repayment of a loan, and the disallowance made was based on incorrect reasoning.
Note: It is a system-generated summary and is for quick reference only.