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...
Administrative and establishment expenses incurred to keep a co-operative society in existence, meet statutory compliance, and preserve its affairs were held deductible against interest income on a real-income basis; the Tribunal also noted that any related business loss could be set off against income under another head. The disallowance was deleted. On self-assessment tax, the Tribunal found that credit had been given only for TDS despite payment of self-assessment tax, treated the omission as a mistake apparent from the record, and directed verification and grant of credit. The appeal was partly allowed.
Administrative and establishment expenses incurred to keep a co-operative society in existence, meet statutory compliance, and preserve its affairs were held deductible against interest income on a real-income basis; the Tribunal also noted that any related business loss could be set off against income under another head. The disallowance was deleted. On self-assessment tax, the Tribunal found that credit had been given only for TDS despite payment of self-assessment tax, treated the omission as a mistake apparent from the record, and directed verification and grant of credit. The appeal was partly allowed.
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