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...
Speculative loss or not - Determine the nature of losses on forward foreign exchange contracts and foreign exchange derivative contracts - the tribunal found the evidence provided by the appellant to be insufficient in establishing the nature of the losses. It highlighted discrepancies in the claimed amounts and noted a lack of clarity regarding the cancellation of contracts. Consequently, the tribunal set aside the CIT(A)'s decision and remanded the issue for further examination. It emphasized the importance of establishing a direct connection between the transactions and the appellant's business activities.
Speculative loss or not - Determine the nature of losses on forward foreign exchange contracts and foreign exchange derivative contracts - the tribunal found the evidence provided by the appellant to be insufficient in establishing the nature of the losses. It highlighted discrepancies in the claimed amounts and noted a lack of clarity regarding the cancellation of contracts. Consequently, the tribunal set aside the CIT(A)'s decision and remanded the issue for further examination. It emphasized the importance of establishing a direct connection between the transactions and the appellant's business activities.
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