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...
Deduction u/s 43B - Payment of Excise duty - double deduction or not - The High Court held that, Section 43B of the Act, which came to be introduced from Assessment Year 1984- 1985 onwards, provides that the excise duty would be deductible only on the payment basis in the year in which it is actually paid. Therefore, the Tribunal was not correct in coming to a conclusion that this amount would amount to double deduction.
Deduction u/s 43B - Payment of Excise duty - double deduction or not - The High Court held that, Section 43B of the Act, which came to be introduced from Assessment Year 1984- 1985 onwards, provides that the excise duty would be deductible only on the payment basis in the year in which it is actually paid. Therefore, the Tribunal was not correct in coming to a conclusion that this amount would amount to double deduction.
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