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 ITAT dismissed the revenue's appeal against the CIT(A)'s order deleting the addition made u/s 28(iv) for assets received free of cost from the assessee's associated enterprise (AE). The assets were used by the assessee for providing services to its AE on a cost-plus basis, with depreciation on these assets included in the cost base per the Advance Pricing Agreement. As the assessee received remuneration from its AE after mark-up on this cost base, the ITAT held that no benefit arose to the assessee from using these assets provided by the AE. The ITAT also dismissed the other grounds raised by the revenue regarding reimbursement to seconded employees and the low tax effect, upholding the CIT(A)'s order.
The ITAT dismissed the revenue's appeal against the CIT(A)'s order deleting the addition made u/s 28(iv) for assets received free of cost from the assessee's associated enterprise (AE). The assets were used by the assessee for providing services to its AE on a cost-plus basis, with depreciation on these assets included in the cost base per the Advance Pricing Agreement. As the assessee received remuneration from its AE after mark-up on this cost base, the ITAT held that no benefit arose to the assessee from using these assets provided by the AE. The ITAT also dismissed the other grounds raised by the revenue regarding reimbursement to seconded employees and the low tax effect, upholding the CIT(A)'s order.
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