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...
Deduction of tax from salary arrears appropriated for transfer to pension corpus set up under pension regulations. Constitutionality of Explanation to Section 17(2)(ii)(c) of Income Tax Act 1961 and relevant circulars challenged. High Court held the issue identical to previous case, extended liberty to petitioners to make requests for determination of tax deduction rate. Interim injunction to continue till specified date or disposal of representations. For house rent allowance arising from bipartite settlement, same direction applied as the legal position is identical.
Deduction of tax from salary arrears appropriated for transfer to pension corpus set up under pension regulations. Constitutionality of Explanation to Section 17(2)(ii)(c) of Income Tax Act 1961 and relevant circulars challenged. High Court held the issue identical to previous case, extended liberty to petitioners to make requests for determination of tax deduction rate. Interim injunction to continue till specified date or disposal of representations. For house rent allowance arising from bipartite settlement, same direction applied as the legal position is identical.
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