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...
HC upheld revision under s.263 regarding treatment of provision for doubtful debts in computing book profits under s.115-JB. AO's acceptance of assessee's claim was mechanical, without examining why provision for doubtful assets was claimed as deduction despite not being debited to provision account. Amount was merely shown as reduction from trade receivables for disclosure, not as written-off debts. Assessee maintained recovery hopes. PCIT's jurisdiction exercise directing re-examination was justified. Tribunal correctly analyzed legal position, finding no illegality in CIT's order. HC found no jurisdictional infirmity, ruling against assessee's appeal.
HC upheld revision under s.263 regarding treatment of provision for doubtful debts in computing book profits under s.115-JB. AO's acceptance of assessee's claim was mechanical, without examining why provision for doubtful assets was claimed as deduction despite not being debited to provision account. Amount was merely shown as reduction from trade receivables for disclosure, not as written-off debts. Assessee maintained recovery hopes. PCIT's jurisdiction exercise directing re-examination was justified. Tribunal correctly analyzed legal position, finding no illegality in CIT's order. HC found no jurisdictional infirmity, ruling against assessee's appeal.
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