Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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The appeals pertain to assessments for the years 2015-16, 2016-17, and 2017-18. This case involves multiple legal and factual issues related to income tax assessments for a banking institution, focusing on disallowances and write-offs. - The tribunal's decision touches upon complex aspects of tax law, including the interpretation of provisions related to bad debts, CSR expenses, ESOS, depreciation on investments, and others. Each issue involves interpreting specific sections of the Income Tax Act, considering the factual circumstances of the bank's operations and the legal precedents.
The appeals pertain to assessments for the years 2015-16, 2016-17, and 2017-18. This case involves multiple legal and factual issues related to income tax assessments for a banking institution, focusing on disallowances and write-offs. - The tribunal's decision touches upon complex aspects of tax law, including the interpretation of provisions related to bad debts, CSR expenses, ESOS, depreciation on investments, and others. Each issue involves interpreting specific sections of the Income Tax Act, considering the factual circumstances of the bank's operations and the legal precedents.
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