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 adjudicated expenditure classification for machinery hydraulic system replacement. The tribunal determined that replacement of hydraulic system with electrical control panel for a second-hand imported machine constitutes capital expenditure rather than revenue expenditure. Despite partial machine component replacement, the tribunal concluded the expenditure provides enduring benefit and enhances machine functionality. The expenditure was deemed capital in nature, rendering the assessee eligible for depreciation under applicable statutory provisions. The tribunal relied on precedential interpretation and upheld the capital expenditure classification, effectively deciding against the assessee's revenue expenditure claim.
ITAT adjudicated expenditure classification for machinery hydraulic system replacement. The tribunal determined that replacement of hydraulic system with electrical control panel for a second-hand imported machine constitutes capital expenditure rather than revenue expenditure. Despite partial machine component replacement, the tribunal concluded the expenditure provides enduring benefit and enhances machine functionality. The expenditure was deemed capital in nature, rendering the assessee eligible for depreciation under applicable statutory provisions. The tribunal relied on precedential interpretation and upheld the capital expenditure classification, effectively deciding against the assessee's revenue expenditure claim.
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