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...
Revision u/s 263 - CSR expenses - admissibility as the deduction u/s 37(1) - The High Court concurred with the findings of the ITAT that the assessing officer had adequately inquired into the CSR expenses. It affirmed that the expenses were legitimately claimed by the respondent and were not erroneous. The Court emphasized that no substantial question of law arose in this factual matter, leading to the dismissal of the appeal.
Revision u/s 263 - CSR expenses - admissibility as the deduction u/s 37(1) - The High Court concurred with the findings of the ITAT that the assessing officer had adequately inquired into the CSR expenses. It affirmed that the expenses were legitimately claimed by the respondent and were not erroneous. The Court emphasized that no substantial question of law arose in this factual matter, leading to the dismissal of the appeal.
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