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. 32AB - rental income - The court analyzes the definition of "eligible business or profession" under Section 32AB(2)(i) and determines that it encompasses a wide range of activities beyond manufacturing or production. The inclusion of rental income within this definition is justified. - The court emphasizes that eligible business includes all income except that specifically excluded. Rental income, being part of the appellant's business income, is thus eligible for deduction under Section 32AB. - Consequently, the court rules in favor of the appellant, stating that the rental income assessed under the head "Income from house property" qualifies for deduction under Section 32AB of the Act.
Deduction u/s. 32AB - rental income - The court analyzes the definition of "eligible business or profession" under Section 32AB(2)(i) and determines that it encompasses a wide range of activities beyond manufacturing or production. The inclusion of rental income within this definition is justified. - The court emphasizes that eligible business includes all income except that specifically excluded. Rental income, being part of the appellant's business income, is thus eligible for deduction under Section 32AB. - Consequently, the court rules in favor of the appellant, stating that the rental income assessed under the head "Income from house property" qualifies for deduction under Section 32AB of the Act.
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