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 partially allowed the appeal, holding that the transaction with Kamineni Health Care Pvt. Ltd. was an investment, not a loan, thereby deleting the disallowance of interest expenses. For the loan to United Steel Allied Ind Private Limited, the Tribunal upheld the CIT(A)'s view, directing the AO to levy interest for the actual loan period. The Tribunal found the assessee failed to substantiate claims of commercial exigency or business connection between the companies, thus treating the advances as loans under section 36(1)(iii) of the Income Tax Act. The appeal was consequently partly allowed with specific directions to the Assessing Officer.
ITAT partially allowed the appeal, holding that the transaction with Kamineni Health Care Pvt. Ltd. was an investment, not a loan, thereby deleting the disallowance of interest expenses. For the loan to United Steel Allied Ind Private Limited, the Tribunal upheld the CIT(A)'s view, directing the AO to levy interest for the actual loan period. The Tribunal found the assessee failed to substantiate claims of commercial exigency or business connection between the companies, thus treating the advances as loans under section 36(1)(iii) of the Income Tax Act. The appeal was consequently partly allowed with specific directions to the Assessing Officer.
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