Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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Assessee, a company paying taxes at fixed rate, filed claim for prior period depreciation. ITAT held allowance of prior period depreciation claim was tax neutral exercise, not resulting in revenue loss. Assessee entitled to claim unabsorbed depreciation of preceding year as depreciation of succeeding year u/s 32(2). Revisionary jurisdiction u/s 263 unwarranted as assessment order not erroneous causing prejudice to revenue. However, ITAT confirmed PCIT's order regarding non-examination of TDS on rent expenses by AO u/s 40(a)(ia), holding assessment order erroneous on this count. Appeal partly allowed.
Assessee, a company paying taxes at fixed rate, filed claim for prior period depreciation. ITAT held allowance of prior period depreciation claim was tax neutral exercise, not resulting in revenue loss. Assessee entitled to claim unabsorbed depreciation of preceding year as depreciation of succeeding year u/s 32(2). Revisionary jurisdiction u/s 263 unwarranted as assessment order not erroneous causing prejudice to revenue. However, ITAT confirmed PCIT's order regarding non-examination of TDS on rent expenses by AO u/s 40(a)(ia), holding assessment order erroneous on this count. Appeal partly allowed.
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