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...
Belated filing of Form 10CCB did not, by itself, justify denial of deduction under section 80IA where the return was filed in time and the audit report was on record before processing under section 143(1). The Tribunal held that filing Form 10CCB by the due date is a procedural requirement, and once the report was furnished before issuance of the intimation, the CPC was bound to examine it. On that basis, the Commissioner (Appeals)' order allowing the deduction was upheld and the Revenue's challenge to the disallowance failed.
Belated filing of Form 10CCB did not, by itself, justify denial of deduction under section 80IA where the return was filed in time and the audit report was on record before processing under section 143(1). The Tribunal held that filing Form 10CCB by the due date is a procedural requirement, and once the report was furnished before issuance of the intimation, the CPC was bound to examine it. On that basis, the Commissioner (Appeals)' order allowing the deduction was upheld and the Revenue's challenge to the disallowance failed.
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