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 High Court examined various issues concerning the calculation of deduction u/s 80IC, eligibility for the deduction, disallowance of royalty payments, and treatment of income from house property. The key points are: The assessee is eligible for the deduction u/s 80IC as it established the manufacturing unit before amalgamation, and Section 80IC(4) is not applicable. The royalty payments were rightly allowed as the expenses were for enduring benefit and capital in nature, following the Hero Honda case. The rental income should be taxed under 'income from house property' and not 'income from other sources,' as the assessee earned rental income by letting out its property, irrespective of the agreement's nomenclature. The Assessing Officer was directed to tax the rental income under 'income from house property' as per law.
The High Court examined various issues concerning the calculation of deduction u/s 80IC, eligibility for the deduction, disallowance of royalty payments, and treatment of income from house property. The key points are: The assessee is eligible for the deduction u/s 80IC as it established the manufacturing unit before amalgamation, and Section 80IC(4) is not applicable. The royalty payments were rightly allowed as the expenses were for enduring benefit and capital in nature, following the Hero Honda case. The rental income should be taxed under 'income from house property' and not 'income from other sources,' as the assessee earned rental income by letting out its property, irrespective of the agreement's nomenclature. The Assessing Officer was directed to tax the rental income under 'income from house property' as per law.
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