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 held that the assessee had actually declared dividend of Rs. 22.67 crores and paid DDT of Rs. 4.61 crores thereon, and that the higher figure of Rs. 27.26 crores in the ROI was an inadvertent inclusion of DDT in the dividend figure. ITAT noted that the assessee had substantiated this with financial statements before CPC and the AO, and that the AO's reliance solely on the ROI figure was unjustified. The addition made towards excess DDT liability was therefore held to be unsustainable and directed to be deleted. On depreciation for assets acquired pursuant to demerger from a state entity, ITAT followed its earlier years' decisions and upheld the assessee's depreciation claim, allowing the appeal.
ITAT held that the assessee had actually declared dividend of Rs. 22.67 crores and paid DDT of Rs. 4.61 crores thereon, and that the higher figure of Rs. 27.26 crores in the ROI was an inadvertent inclusion of DDT in the dividend figure. ITAT noted that the assessee had substantiated this with financial statements before CPC and the AO, and that the AO's reliance solely on the ROI figure was unjustified. The addition made towards excess DDT liability was therefore held to be unsustainable and directed to be deleted. On depreciation for assets acquired pursuant to demerger from a state entity, ITAT followed its earlier years' decisions and upheld the assessee's depreciation claim, allowing the appeal.
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