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...
Deduction u/s 80IA - The Revenue contended that the filing of Form 10CCB within the prescribed date is mandatory, while the assessee argued otherwise. The Tribunal, after analyzing the relevant legal provisions, concluded that while the filing of Form 10CCB is mandatory, adhering to the prescribed due date is not. The Tribunal also noted that the CIT(A) failed to properly consider legal precedents and independently assess the facts of the case. Consequently, the Tribunal set aside the CIT(A)'s decision and remanded the matter for fresh consideration.
Deduction u/s 80IA - The Revenue contended that the filing of Form 10CCB within the prescribed date is mandatory, while the assessee argued otherwise. The Tribunal, after analyzing the relevant legal provisions, concluded that while the filing of Form 10CCB is mandatory, adhering to the prescribed due date is not. The Tribunal also noted that the CIT(A) failed to properly consider legal precedents and independently assess the facts of the case. Consequently, the Tribunal set aside the CIT(A)'s decision and remanded the matter for fresh consideration.
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