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...
Amendment to clause (c) of section 200A relating to imposition of late fee under section 234E applies prospectively from 01.06.2015; therefore late fee for belated TDS quarterly returns must be calculated only from that date to the date of filing. Coordinate bench authority directs recalculation of late fee from 01.06.2015; appellate order set aside and matter remitted to the jurisdictional TDS officer to perform the specified recalculation and determine payable late fee for the relevant return period.
Amendment to clause (c) of section 200A relating to imposition of late fee under section 234E applies prospectively from 01.06.2015; therefore late fee for belated TDS quarterly returns must be calculated only from that date to the date of filing. Coordinate bench authority directs recalculation of late fee from 01.06.2015; appellate order set aside and matter remitted to the jurisdictional TDS officer to perform the specified recalculation and determine payable late fee for the relevant return period.
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