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 - adjustment of rent/lease equalization reserve u/s 115JB of the Act - The Assessee contended that the reserve was not covered under Explanation 1(b) or 1(c) to section 115JB of the Act. The Tribunal agreed, referencing judgments that clarified such reserves are not to be added back while computing book profits under section 115JA. Hence, the addition made by the Assessing Officer deleted.
MAT computation - adjustment of rent/lease equalization reserve u/s 115JB of the Act - The Assessee contended that the reserve was not covered under Explanation 1(b) or 1(c) to section 115JB of the Act. The Tribunal agreed, referencing judgments that clarified such reserves are not to be added back while computing book profits under section 115JA. Hence, the addition made by the Assessing Officer deleted.
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