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...
After the 01-04-2016 amendment, weighted deduction for in-house R&D under section 35(2AB) was confined to the expenditure quantified by the DSIR in Form 3CL, and the Assessing Officer could not allow a higher amount. MEIS receipts treated as capital receipts were not liable to addition in book profit under section 115JB unless they fell within the specific Explanation 1 adjustments, and a capital receipt not debited to profit and loss could not be added merely because of accounting treatment. Loss on investment in a wholly owned subsidiary was treated as business loss where the investment was made on commercial expediency to further business operations. Both the assessee's and Revenue's appeals were dismissed.
After the 01-04-2016 amendment, weighted deduction for in-house R&D under section 35(2AB) was confined to the expenditure quantified by the DSIR in Form 3CL, and the Assessing Officer could not allow a higher amount. MEIS receipts treated as capital receipts were not liable to addition in book profit under section 115JB unless they fell within the specific Explanation 1 adjustments, and a capital receipt not debited to profit and loss could not be added merely because of accounting treatment. Loss on investment in a wholly owned subsidiary was treated as business loss where the investment was made on commercial expediency to further business operations. Both the assessee's and Revenue's appeals were dismissed.
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