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...
Non-payment of tax for Assessment Years 2005-06 and 2006-07 - Liability to pay interest u/s 234B. Prior to the insertion of proviso to Section 209(1), if the payer defaulted in deducting tax at source from payments to non-residents, the non-resident was not absolved from paying taxes, and the question of advance tax payment did not arise. The Supreme Court disposed of the appeal due to low tax effect, keeping any question of law open. Pending applications were also disposed of.
Non-payment of tax for Assessment Years 2005-06 and 2006-07 - Liability to pay interest u/s 234B. Prior to the insertion of proviso to Section 209(1), if the payer defaulted in deducting tax at source from payments to non-residents, the non-resident was not absolved from paying taxes, and the question of advance tax payment did not arise. The Supreme Court disposed of the appeal due to low tax effect, keeping any question of law open. Pending applications were also disposed of.
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