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...
TDS on interest arising from Motor Accidents Claim - Validity of the order of the Motor Accidents Claims Tribunal issuing directions to refund by the Insurance Company of amounts deducted as TDS and already credited to the Income Tax Department - The High Court held that, there can be no spread over of the interest income in the years in which it accrued after death of the person, which resulted in the compensation being awarded. HC observed that, Section 194A(3)(ix) speaks of such exemption from deduction of tax, from the interest income, when the aggregate amount of such income credited or paid during the financial year exceeds Rs. 50,000/-. Hence, the income has to be found to have accrued only on the date of payment or credit. - While noting the subsequent amendment coming into force from 01.06.2015, no TDS can be deducted even on the interest component, the order of Tribunal reversed.
TDS on interest arising from Motor Accidents Claim - Validity of the order of the Motor Accidents Claims Tribunal issuing directions to refund by the Insurance Company of amounts deducted as TDS and already credited to the Income Tax Department - The High Court held that, there can be no spread over of the interest income in the years in which it accrued after death of the person, which resulted in the compensation being awarded. HC observed that, Section 194A(3)(ix) speaks of such exemption from deduction of tax, from the interest income, when the aggregate amount of such income credited or paid during the financial year exceeds Rs. 50,000/-. Hence, the income has to be found to have accrued only on the date of payment or credit. - While noting the subsequent amendment coming into force from 01.06.2015, no TDS can be deducted even on the interest component, the order of Tribunal reversed.
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