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...
Addition to the book profit u/s 115JB for the amount disallowed u/s 14A r.w. Rule 8D - the tribunal noted that the AO had made the disallowance under Section 14A, but the assessee hadn't adjusted this amount while computing the book profit. The tribunal upheld the addition to the book profit, affirming the decision of the CIT(A) and partly allowing the Revenue's appeal on this ground.
Addition to the book profit u/s 115JB for the amount disallowed u/s 14A r.w. Rule 8D - the tribunal noted that the AO had made the disallowance under Section 14A, but the assessee hadn't adjusted this amount while computing the book profit. The tribunal upheld the addition to the book profit, affirming the decision of the CIT(A) and partly allowing the Revenue's appeal on this ground.
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