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...
TDS u/s 194C - payments of purchase to various vendors - Non deduction of TDS - Upon analysis, the Appellate Tribunal agreed with the assessee, ruling that the transactions were indeed purchases of finished goods. It noted that the manufacturers independently sourced raw materials and produced goods according to the specifications provided. Furthermore, the Tribunal found that the assessee's control over production was limited, as evidenced by the return of rejected goods to the vendors. Tribunal dismissed the revenue's appeal.
TDS u/s 194C - payments of purchase to various vendors - Non deduction of TDS - Upon analysis, the Appellate Tribunal agreed with the assessee, ruling that the transactions were indeed purchases of finished goods. It noted that the manufacturers independently sourced raw materials and produced goods according to the specifications provided. Furthermore, the Tribunal found that the assessee's control over production was limited, as evidenced by the return of rejected goods to the vendors. Tribunal dismissed the revenue's appeal.
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