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 assessee bank made provisions for group gratuity and leave encashment by debiting expenses in its books, but these provisions were never treated as real expenses for income tax purposes. The AO made additions for the difference between the book provisions and actuarial valuations. The ITAT held that the expenses debited pertained to the assessment year and were real expenses, not provisions. The AO's findings that the amounts did not pertain to the year were perverse. Only real income is taxable, not provisions, as held in Shoorji Vallabhdas case. The assessee did not claim notional expenses to reduce profits. The AO's additions were deleted.
The assessee bank made provisions for group gratuity and leave encashment by debiting expenses in its books, but these provisions were never treated as real expenses for income tax purposes. The AO made additions for the difference between the book provisions and actuarial valuations. The ITAT held that the expenses debited pertained to the assessment year and were real expenses, not provisions. The AO's findings that the amounts did not pertain to the year were perverse. Only real income is taxable, not provisions, as held in Shoorji Vallabhdas case. The assessee did not claim notional expenses to reduce profits. The AO's additions were deleted.
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