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 held that income tax exemption under Section 10(26) for Scheduled Tribes is only applicable when income accrues in specified areas under Sixth Schedule. The interest on compensation was deemed to have accrued in North Lakhimpur, Assam, which does not fall within Sixth Schedule areas. Railway Tribunal's orders directing NF Railway to refund tax deducted at source were set aside, as mere tribal status from Arunachal Pradesh was insufficient grounds for exemption. The geographical location of income accrual, not tribal status alone, determines eligibility for tax exemption under Section 10(26).
HC held that income tax exemption under Section 10(26) for Scheduled Tribes is only applicable when income accrues in specified areas under Sixth Schedule. The interest on compensation was deemed to have accrued in North Lakhimpur, Assam, which does not fall within Sixth Schedule areas. Railway Tribunal's orders directing NF Railway to refund tax deducted at source were set aside, as mere tribal status from Arunachal Pradesh was insufficient grounds for exemption. The geographical location of income accrual, not tribal status alone, determines eligibility for tax exemption under Section 10(26).
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