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...
Adjustment made to the income returned in the intimation made by the CPC u/s 143(1) - exemption u/s 11/12 denied as assessee had failed to furnish the necessary Form 10B one month prior to the due date of filing of return of income u/s 139(1) - procedural v/s mandatory requirement - the assessee had demonstrated to the ld. CIT(A) that the necessary Form 10B had been prepared much in advance before the due date of filing of return of income and had been filed before the ld. CIT(A) also. - the Tribunal held that the assessee's claim of exemption to its entire income under Sections 11 and 12 of the Act should be allowed.
Adjustment made to the income returned in the intimation made by the CPC u/s 143(1) - exemption u/s 11/12 denied as assessee had failed to furnish the necessary Form 10B one month prior to the due date of filing of return of income u/s 139(1) - procedural v/s mandatory requirement - the assessee had demonstrated to the ld. CIT(A) that the necessary Form 10B had been prepared much in advance before the due date of filing of return of income and had been filed before the ld. CIT(A) also. - the Tribunal held that the assessee's claim of exemption to its entire income under Sections 11 and 12 of the Act should be allowed.
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