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 addressed multiple taxation issues for the assessee across assessment years. Key outcomes include: directing deletion of depreciation disallowance related to demerger, allowing software expenses as revenue expenditure, permitting travel expenses for foreign executives, restricting section 14A disallowance to 2% of dividend income, and restoring certain issues to the Assessing Officer for fresh examination. The Tribunal consistently followed precedent decisions from earlier years, modifying the CIT(A)'s order on several grounds and providing specific directions for computational adjustments in various tax-related matters.
The ITAT addressed multiple taxation issues for the assessee across assessment years. Key outcomes include: directing deletion of depreciation disallowance related to demerger, allowing software expenses as revenue expenditure, permitting travel expenses for foreign executives, restricting section 14A disallowance to 2% of dividend income, and restoring certain issues to the Assessing Officer for fresh examination. The Tribunal consistently followed precedent decisions from earlier years, modifying the CIT(A)'s order on several grounds and providing specific directions for computational adjustments in various tax-related matters.
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