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...
Income taxable in India or not - Salary income - Australia assignment period - incomes deemed to accrue or arise in India as assessee is a non-resident - Despite non-submission of TRC, the Assessee provided alternate evidence supporting his tax residency in Australia. The Tribunal considered this evidence, along with the submissions made during assessment proceedings and objections raised before the DRP. Ultimately, the Tribunal ruled in favor of the Assessee, allowing the exemption claim on the grounds of his residency status and the nature of employment exercised in Australia.
Income taxable in India or not - Salary income - Australia assignment period - incomes deemed to accrue or arise in India as assessee is a non-resident - Despite non-submission of TRC, the Assessee provided alternate evidence supporting his tax residency in Australia. The Tribunal considered this evidence, along with the submissions made during assessment proceedings and objections raised before the DRP. Ultimately, the Tribunal ruled in favor of the Assessee, allowing the exemption claim on the grounds of his residency status and the nature of employment exercised in Australia.
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