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...
MAT computation u/s 115JB - Adjustment for computation of book profits u/s. 115JB on the ground that expenses are unascertained liability. - The Tribunal addressed each provision made by the assessee (for HD commission, ex gratia and bonus, gratuity to HD canvassers, and gratuity), analyzing whether they constituted ascertained or contingent liabilities. It referenced judicial precedents to allow the assessee's claims, emphasizing the principle that provisions based on actuarial valuations are considered ascertained liabilities.
MAT computation u/s 115JB - Adjustment for computation of book profits u/s. 115JB on the ground that expenses are unascertained liability. - The Tribunal addressed each provision made by the assessee (for HD commission, ex gratia and bonus, gratuity to HD canvassers, and gratuity), analyzing whether they constituted ascertained or contingent liabilities. It referenced judicial precedents to allow the assessee's claims, emphasizing the principle that provisions based on actuarial valuations are considered ascertained liabilities.
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