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(4) on wind mills and solar power plants - Whether each windmill and solar power plant installed by the assessee should be considered as separate undertakings or one undertaking? - The Tribunal, referencing its own previous decisions and the lack of any new material facts or judicial precedents, upheld the Commissioner of Income Tax (Appeals)'s ruling. It was concluded that each windmill and solar power plant must be treated as separate undertakings for the calculation of deductions under section 80IA(4), thereby dismissing the Revenue's appeal on this ground. - Furthermore, on Applicability of Notional Brought Forward Losses and Depreciation, the Tribunal followed the principles laid down by the High Courts, which stated that losses from eligible businesses, once set off against other income, cannot be notionally carried forward to reduce the profits of the eligible business in subsequent years for the purpose of computing deduction under section 80IA.
Deduction u/s 80IA(4) on wind mills and solar power plants - Whether each windmill and solar power plant installed by the assessee should be considered as separate undertakings or one undertaking? - The Tribunal, referencing its own previous decisions and the lack of any new material facts or judicial precedents, upheld the Commissioner of Income Tax (Appeals)'s ruling. It was concluded that each windmill and solar power plant must be treated as separate undertakings for the calculation of deductions under section 80IA(4), thereby dismissing the Revenue's appeal on this ground. - Furthermore, on Applicability of Notional Brought Forward Losses and Depreciation, the Tribunal followed the principles laid down by the High Courts, which stated that losses from eligible businesses, once set off against other income, cannot be notionally carried forward to reduce the profits of the eligible business in subsequent years for the purpose of computing deduction under section 80IA.
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