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...
In a transfer pricing dispute concerning the software development services segment, the ITAT held that the Transfer Pricing Officer had not dealt with the five comparables remitted for reconsideration, and that the later DRP consideration did not cure the failure to follow the earlier appellate direction in time. The defect was treated as an irregularity requiring correction, not as a basis to annul the assessment. The Assessing Officer was therefore directed to exclude Acropetal Technologies, E-Zest Solutions, E-Infochips, ICRA Techno Analytics and Persistent Systems and recompute the arm's length price adjustment; the assessment was otherwise left undisturbed.
In a transfer pricing dispute concerning the software development services segment, the ITAT held that the Transfer Pricing Officer had not dealt with the five comparables remitted for reconsideration, and that the later DRP consideration did not cure the failure to follow the earlier appellate direction in time. The defect was treated as an irregularity requiring correction, not as a basis to annul the assessment. The Assessing Officer was therefore directed to exclude Acropetal Technologies, E-Zest Solutions, E-Infochips, ICRA Techno Analytics and Persistent Systems and recompute the arm's length price adjustment; the assessment was otherwise left undisturbed.
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