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 High Court held that the solar plant was put to use for the purpose of business on 20.03.2013 when it started generating electricity, despite being non-functional initially due to defects. Consequently, the assessee was entitled to claim depreciation on the solar plant from the financial year 2012-13 itself, even though synchronization with the grid took place on 20.04.2013 in the subsequent financial year 2013-14. The appeal filed by the Revenue was dismissed.
The High Court held that the solar plant was put to use for the purpose of business on 20.03.2013 when it started generating electricity, despite being non-functional initially due to defects. Consequently, the assessee was entitled to claim depreciation on the solar plant from the financial year 2012-13 itself, even though synchronization with the grid took place on 20.04.2013 in the subsequent financial year 2013-14. The appeal filed by the Revenue was dismissed.
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