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...
Exemption u/s 11 - whether the objects of the trust were charitable? - The High court found that the issue of interpretation of Section 11 was covered by previous rulings and did not raise substantial questions of law. - As for the restriction of denial of benefit under Section 11, the court agreed with the respondent's argument, stating that only income used for the benefit of prohibited persons should be denied exemption. - Regarding the applicability of the Bharat Diamond Bourse case, the court clarified that it did not specify whether the denial of benefit under Section 11 should apply to the entire income or only to diverted funds. - The court admitted the question regarding the eligibility of expenditure incurred on new objects for exemption under Section 11 for further consideration.
Exemption u/s 11 - whether the objects of the trust were charitable? - The High court found that the issue of interpretation of Section 11 was covered by previous rulings and did not raise substantial questions of law. - As for the restriction of denial of benefit under Section 11, the court agreed with the respondent's argument, stating that only income used for the benefit of prohibited persons should be denied exemption. - Regarding the applicability of the Bharat Diamond Bourse case, the court clarified that it did not specify whether the denial of benefit under Section 11 should apply to the entire income or only to diverted funds. - The court admitted the question regarding the eligibility of expenditure incurred on new objects for exemption under Section 11 for further consideration.
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