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...
Depreciation on assets disallowed by authorities due to invoices bearing names of associate company and incorrect dates. Assessee contended ownership transferred via inter-office memos, incorrect invoice dates rectified, assets in use with payments made during assessment year. Business transfer agreement for purchase of running business caused delay in record date of acquisition. No employee cost as operations commenced with directors and assistance from associates, with billing arrangement of cost plus 15% markup to associated enterprise. When revenue accepted based on depreciation plus markup, no reason to deny cost. Authorities erred in disallowing depreciation. Decided in favor of assessee.
Depreciation on assets disallowed by authorities due to invoices bearing names of associate company and incorrect dates. Assessee contended ownership transferred via inter-office memos, incorrect invoice dates rectified, assets in use with payments made during assessment year. Business transfer agreement for purchase of running business caused delay in record date of acquisition. No employee cost as operations commenced with directors and assistance from associates, with billing arrangement of cost plus 15% markup to associated enterprise. When revenue accepted based on depreciation plus markup, no reason to deny cost. Authorities erred in disallowing depreciation. Decided in favor of assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
