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...
Credit of TDS - consideration received for offshore supply of rolling stock, when no corresponding income has been offered for taxation by the assessee - The ITAT cited precedent to assert that TDS credit should be granted regardless of whether the income was directly offered for taxation, as long as TDS was deducted and deposited with the government. - The Tribunal upheld the assessee's entitlement to TDS credit and subsequent refunds, in alignment with previous rulings and provisions of the Income Tax Act.
Credit of TDS - consideration received for offshore supply of rolling stock, when no corresponding income has been offered for taxation by the assessee - The ITAT cited precedent to assert that TDS credit should be granted regardless of whether the income was directly offered for taxation, as long as TDS was deducted and deposited with the government. - The Tribunal upheld the assessee's entitlement to TDS credit and subsequent refunds, in alignment with previous rulings and provisions of the Income Tax Act.
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