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 case deals with transfer pricing adjustments made by the tax authorities regarding international transactions involving sale of Paclitaxel, Disodium Pamidronate, and purchase of Methylene Chloride Soluble (MCS). The tax officer rejected the Transactional Net Margin Method (TNMM) adopted by the assessee and applied the Comparable Uncontrolled Price Method (CUP). The appellate authorities upheld the assessee's use of TNMM for Paclitaxel and Disodium Pamidronate, considering factors u/r 10B(2) of the Income Tax Rules. For MCS, the tax officer determined the cost price per kg as Rs. 32, while the assessee claimed Rs. 4648 per kg based on a cost certificate. The appellate authorities accepted the assessee's cost certificate in the absence of any material challenging its veracity. The High Court found no substantial question of law arising from the factual findings of the lower authorities.
This case deals with transfer pricing adjustments made by the tax authorities regarding international transactions involving sale of Paclitaxel, Disodium Pamidronate, and purchase of Methylene Chloride Soluble (MCS). The tax officer rejected the Transactional Net Margin Method (TNMM) adopted by the assessee and applied the Comparable Uncontrolled Price Method (CUP). The appellate authorities upheld the assessee's use of TNMM for Paclitaxel and Disodium Pamidronate, considering factors u/r 10B(2) of the Income Tax Rules. For MCS, the tax officer determined the cost price per kg as Rs. 32, while the assessee claimed Rs. 4648 per kg based on a cost certificate. The appellate authorities accepted the assessee's cost certificate in the absence of any material challenging its veracity. The High Court found no substantial question of law arising from the factual findings of the lower authorities.
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