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...
Denial of deduction claimed u/s 80P (2)(d) - AO disallowed the benefit by invoking the provision of section 154 for rectification of mistake change of opinion - interest derived by the Co-operative society from its investments with any other co-operative society - The ITAT held that considering the provisions of section 22 of Regional Rural Bank Act, wherein the status of the banks established are of the co-operative society the assessee is entitled for the exemption on the interest earned on the deposits. - The allowability of deduction of interest u/s. 80P(2)(d) decided in favour of assessee on merit itslef.
Denial of deduction claimed u/s 80P (2)(d) - AO disallowed the benefit by invoking the provision of section 154 for rectification of mistake change of opinion - interest derived by the Co-operative society from its investments with any other co-operative society - The ITAT held that considering the provisions of section 22 of Regional Rural Bank Act, wherein the status of the banks established are of the co-operative society the assessee is entitled for the exemption on the interest earned on the deposits. - The allowability of deduction of interest u/s. 80P(2)(d) decided in favour of assessee on merit itslef.
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