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...
Taxability of receipts from offshore supply of equipments - offshore supply made to Indian PSU’s which the assessee had claimed to be not chargeable to tax under Indian Taxation - Assessee company is tax resident of China - The Tribunal analyzed the terms of the contracts and previous tribunal decisions, which indicated that the transfer of title over the goods occurred outside India, making the receipts non-taxable in India. The court emphasized that the Assessing Officer's bifurcation lacked a rational basis and evidence, rendering it impermissible.
Taxability of receipts from offshore supply of equipments - offshore supply made to Indian PSU’s which the assessee had claimed to be not chargeable to tax under Indian Taxation - Assessee company is tax resident of China - The Tribunal analyzed the terms of the contracts and previous tribunal decisions, which indicated that the transfer of title over the goods occurred outside India, making the receipts non-taxable in India. The court emphasized that the Assessing Officer's bifurcation lacked a rational basis and evidence, rendering it impermissible.
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