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...
Carry forward and set off of business losses u/s 32(2) is subject to the provisions of Sections 72(2) and 72(3). Depreciation allowance carried forward u/s 32(2), though deemed a business loss for Sections 71 and 72, can only be set off against profits or gains from any business or profession, and not against income from other sources. Section 72 is not always subject to Section 71, despite Section 32(2) permitting carry forward of depreciation allowance subject to Section 72. The High Court dismissed the writ petition, finding no error warranting exercise of jurisdiction under Article 226 of the Constitution.
Carry forward and set off of business losses u/s 32(2) is subject to the provisions of Sections 72(2) and 72(3). Depreciation allowance carried forward u/s 32(2), though deemed a business loss for Sections 71 and 72, can only be set off against profits or gains from any business or profession, and not against income from other sources. Section 72 is not always subject to Section 71, despite Section 32(2) permitting carry forward of depreciation allowance subject to Section 72. The High Court dismissed the writ petition, finding no error warranting exercise of jurisdiction under Article 226 of the Constitution.
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