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...
The Appellate Tribunal considered a case involving revision u/s 263 of the Act related to annuity payments made to LIC. The employer did not make the annuity payment; it was made on employees' request from VRS amount. The claim for exemption u/s 10(10CC) and u/s 10(10BB) was found incorrect as per PCIT's enquiry. AO allowed exemptions without verifying from the employer, leading to an erroneous order. The annuity amount paid to LIC was deemed taxable as salary per Supreme Court ruling. The AO's failure to conduct proper inquiries rendered the order prejudicial to revenue. Jurisdiction u/s 263 was upheld, dismissing the assessee's appeals.
The Appellate Tribunal considered a case involving revision u/s 263 of the Act related to annuity payments made to LIC. The employer did not make the annuity payment; it was made on employees' request from VRS amount. The claim for exemption u/s 10(10CC) and u/s 10(10BB) was found incorrect as per PCIT's enquiry. AO allowed exemptions without verifying from the employer, leading to an erroneous order. The annuity amount paid to LIC was deemed taxable as salary per Supreme Court ruling. The AO's failure to conduct proper inquiries rendered the order prejudicial to revenue. Jurisdiction u/s 263 was upheld, dismissing the assessee's appeals.
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