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...
Disallowance of weighted deduction u/s. 35(2AB) - research and development (R&D) expenditure - The Income Tax Appellate Tribunal (ITAT) considered the arguments presented by both parties and examined the relevant documentation, including Form-3CM and Form-3CL, which certified the R&D expenditure incurred by the assessee. - The ITAT allowed the appeals filed by the assessee. It directed the Assessing Officer to allow the actual expenditure incurred for in-house R&D facilities, as certified by the Ministry of Science and Technology, without any weighted deduction.
Disallowance of weighted deduction u/s. 35(2AB) - research and development (R&D) expenditure - The Income Tax Appellate Tribunal (ITAT) considered the arguments presented by both parties and examined the relevant documentation, including Form-3CM and Form-3CL, which certified the R&D expenditure incurred by the assessee. - The ITAT allowed the appeals filed by the assessee. It directed the Assessing Officer to allow the actual expenditure incurred for in-house R&D facilities, as certified by the Ministry of Science and Technology, without any weighted deduction.
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