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...
The Income Tax Appellate Tribunal allowed the assessee's appeal and directed the Assessing Officer to permit the deduction of bad debts claimed u/s 37(1) of the Income Tax Act. The Tribunal held that the authorities below misunderstood the facts and failed to appreciate the prevailing business scenario. Venturing into diverse sectors is common for large corporate houses. The assessee's investment in the subsidiary was part of its business, and after a long gestation period, the question of it not being part of the assessee's business was ruled out. The Tribunal relied on Supreme Court judgments to strengthen the assessee's case.
The Income Tax Appellate Tribunal allowed the assessee's appeal and directed the Assessing Officer to permit the deduction of bad debts claimed u/s 37(1) of the Income Tax Act. The Tribunal held that the authorities below misunderstood the facts and failed to appreciate the prevailing business scenario. Venturing into diverse sectors is common for large corporate houses. The assessee's investment in the subsidiary was part of its business, and after a long gestation period, the question of it not being part of the assessee's business was ruled out. The Tribunal relied on Supreme Court judgments to strengthen the assessee's case.
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