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...
Anonymous donations maintained record of identity, address, PAN, Aadhaar details of donors, hence provisions of section 115BBC not applicable. AO doubted genuineness without following procedure, providing opportunity; CIT(A) rightly deleted addition. Tied-up grants not voluntary contributions, not income; no requirement to file Form 9A when application doesn't fall short of 85% income from trust property. AO wrongly added unspent grants shown in balance sheet but not income and expenditure account; CIT(A) correctly deleted addition. No interference required.
Anonymous donations maintained record of identity, address, PAN, Aadhaar details of donors, hence provisions of section 115BBC not applicable. AO doubted genuineness without following procedure, providing opportunity; CIT(A) rightly deleted addition. Tied-up grants not voluntary contributions, not income; no requirement to file Form 9A when application doesn't fall short of 85% income from trust property. AO wrongly added unspent grants shown in balance sheet but not income and expenditure account; CIT(A) correctly deleted addition. No interference required.
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