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...
ITAT ruled favorably on multiple issues for the banking assessee. The tribunal allowed deduction under s.36(1)(viia) for NPA provisions, holding them equivalent to provisions for bad and doubtful debts. For s.14A disallowance, matter was remanded to examine administrative expenses allocation despite interest-free funds exceeding investments. Deduction under s.36(1)(vii) was permitted following prior precedent. RBI penalty payment was deemed allowable under s.37 as not being for legal infraction. Interest on Innovative Perpetual Debt Instruments (IPDI) qualified for deduction under s.36(1)(iii), recognizing these hybrid instruments as legitimate business borrowings despite their perpetual nature and discretionary payout features. The ruling primarily followed established banking sector precedents and emphasized substance over form.
ITAT ruled favorably on multiple issues for the banking assessee. The tribunal allowed deduction under s.36(1)(viia) for NPA provisions, holding them equivalent to provisions for bad and doubtful debts. For s.14A disallowance, matter was remanded to examine administrative expenses allocation despite interest-free funds exceeding investments. Deduction under s.36(1)(vii) was permitted following prior precedent. RBI penalty payment was deemed allowable under s.37 as not being for legal infraction. Interest on Innovative Perpetual Debt Instruments (IPDI) qualified for deduction under s.36(1)(iii), recognizing these hybrid instruments as legitimate business borrowings despite their perpetual nature and discretionary payout features. The ruling primarily followed established banking sector precedents and emphasized substance over form.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
