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 194J/195 - whether payment of roaming charges falls within the meaning of “FTS" - The Tribunal held that payment of roaming charges is neither in the nature of ‘FTS’ nor ‘Royalty’ and hence did not require TDS u/s 194J of the Act or under the treaties.
TDS u/s 194J/195 - whether payment of roaming charges falls within the meaning of “FTS" - The Tribunal held that payment of roaming charges is neither in the nature of ‘FTS’ nor ‘Royalty’ and hence did not require TDS u/s 194J of the Act or under the treaties.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
