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...
A partnership firm is a separate taxable entity under the Income-tax Act only from the date it comes into existence, so it cannot claim interest expenditure attributable to an earlier period when the business was still a proprietorship concern. The Tribunal held that the firm, having commenced on 15.06.2014, was entitled to deduct expenses only for its own period of existence and not for 01.04.2014 to 14.06.2014. The proportionate disallowance of interest made by the Assessing Officer and upheld in first appeal was therefore sustained. The delay in filing the appeal was condoned on sufficient cause.
A partnership firm is a separate taxable entity under the Income-tax Act only from the date it comes into existence, so it cannot claim interest expenditure attributable to an earlier period when the business was still a proprietorship concern. The Tribunal held that the firm, having commenced on 15.06.2014, was entitled to deduct expenses only for its own period of existence and not for 01.04.2014 to 14.06.2014. The proportionate disallowance of interest made by the Assessing Officer and upheld in first appeal was therefore sustained. The delay in filing the appeal was condoned on sufficient cause.
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