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...
Section 2(1-A) amended retrospectively to restrict agricultural land exemption to rural areas, introducing concept of "urban agricultural land" under "capital asset" definition. Tribunal refused to admit additional grounds on merits of Section 115JB MAT computation. Once agricultural land income exempt, cannot be added to book profits for MAT. Tribunal should have allowed submissions before dismissing grounds. HC allowed appeal, set aside Tribunal order, answered legal question in appellant's favor.
Section 2(1-A) amended retrospectively to restrict agricultural land exemption to rural areas, introducing concept of "urban agricultural land" under "capital asset" definition. Tribunal refused to admit additional grounds on merits of Section 115JB MAT computation. Once agricultural land income exempt, cannot be added to book profits for MAT. Tribunal should have allowed submissions before dismissing grounds. HC allowed appeal, set aside Tribunal order, answered legal question in appellant's favor.
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