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...
Rejection of Revision application u/s 264 - Exemption u/s 11 denied to assessee - benefits denied merely on the ground that the donor has deducted TDS u/s 194C and 194J while allocating requisite grants to the assessee - scope of principle of consistency in taxation matters - The High Court held that, the deduction of TDS under specific sections was deemed an insufficient basis to deny exemptions under Sections 11 and 12. The court underscored that such deductions, possibly made under a misconception by the donors, should not adversely affect the Foundation's eligibility for exemptions. - Benefit of exemption allowed.
Rejection of Revision application u/s 264 - Exemption u/s 11 denied to assessee - benefits denied merely on the ground that the donor has deducted TDS u/s 194C and 194J while allocating requisite grants to the assessee - scope of principle of consistency in taxation matters - The High Court held that, the deduction of TDS under specific sections was deemed an insufficient basis to deny exemptions under Sections 11 and 12. The court underscored that such deductions, possibly made under a misconception by the donors, should not adversely affect the Foundation's eligibility for exemptions. - Benefit of exemption allowed.
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