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...
Grant of approval u/s. 80G(5) - denial of approval as application was not filed within six months from the date of grant of provisional approval - The Tribunal observed that the Act does not empower it to condone delays in such matters, unlike provisions for other sections. Citing legal precedents, it affirmed that without explicit statutory authority, delay condonation is not permissible. Consequently, the denial of approval u/s. 80G(5) by the ld. CIT, Exemption was upheld.
Grant of approval u/s. 80G(5) - denial of approval as application was not filed within six months from the date of grant of provisional approval - The Tribunal observed that the Act does not empower it to condone delays in such matters, unlike provisions for other sections. Citing legal precedents, it affirmed that without explicit statutory authority, delay condonation is not permissible. Consequently, the denial of approval u/s. 80G(5) by the ld. CIT, Exemption was upheld.
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