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...
This is a summary of an Income Tax Appellate Tribunal (ITAT) order dealing with various transfer pricing and deduction issues. The key points are: Transfer pricing adjustments were deleted for trademark fee, outstanding receivables, and purchase of finished goods transactions based on the application of appropriate methods and factual findings. The regional service charges and accounting support services transactions were remitted to the Transfer Pricing Officer for fresh adjudication after considering the assessee's submissions. The disallowance of 30% advertising and brand-building expenses was decided in favor of the assessee, following earlier years' ITAT orders. The disallowance of employees' contribution to ESI was upheld based on the Supreme Court's decision in Checkmate Services, as the contributions were deposited after the due dates prescribed under the relevant Act.
This is a summary of an Income Tax Appellate Tribunal (ITAT) order dealing with various transfer pricing and deduction issues. The key points are: Transfer pricing adjustments were deleted for trademark fee, outstanding receivables, and purchase of finished goods transactions based on the application of appropriate methods and factual findings. The regional service charges and accounting support services transactions were remitted to the Transfer Pricing Officer for fresh adjudication after considering the assessee's submissions. The disallowance of 30% advertising and brand-building expenses was decided in favor of the assessee, following earlier years' ITAT orders. The disallowance of employees' contribution to ESI was upheld based on the Supreme Court's decision in Checkmate Services, as the contributions were deposited after the due dates prescribed under the relevant Act.
Note: It is a system-generated summary and is for quick reference only.
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