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...
Advances given to 5 persons without charging interest were for business purposes. Non-installation of machinery or renovation in subsequent period due to non-viability cannot negate the business purpose. Assessee decided not to proceed with its plan due to bad market condition, which is a valid business decision and consequential expenditure cannot be disallowed. Assessee had sufficient interest-free capital exceeding the interest-free advances, hence disallowance of interest is impermissible as per jurisdictional High Court precedents.
Advances given to 5 persons without charging interest were for business purposes. Non-installation of machinery or renovation in subsequent period due to non-viability cannot negate the business purpose. Assessee decided not to proceed with its plan due to bad market condition, which is a valid business decision and consequential expenditure cannot be disallowed. Assessee had sufficient interest-free capital exceeding the interest-free advances, hence disallowance of interest is impermissible as per jurisdictional High Court precedents.
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