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...
Disallowance of VAT expenses - Disallowance as "fee" or "charge" u/s40(a)(iib) - The Assessee, a state government-owned company engaged in the wholesale business of foreign liquor in Chhattisgarh, contested the disallowance. - Referring to the judgment of the Hon’ble Supreme Court in the case of Kerala State Beverages Manufacturing & Marketing Corporation Ltd., the Tribunal held that surcharge on sales tax, including VAT, does not fall within the scope of disallowance under Section 40(a)(iib) of the Income-tax Act, 1961.
Disallowance of VAT expenses - Disallowance as "fee" or "charge" u/s40(a)(iib) - The Assessee, a state government-owned company engaged in the wholesale business of foreign liquor in Chhattisgarh, contested the disallowance. - Referring to the judgment of the Hon’ble Supreme Court in the case of Kerala State Beverages Manufacturing & Marketing Corporation Ltd., the Tribunal held that surcharge on sales tax, including VAT, does not fall within the scope of disallowance under Section 40(a)(iib) of the Income-tax Act, 1961.
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