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...
Unabsorbed depreciation carried forward under Section 32(2) retains the character of current-year loss and may be set off against business income or other income, except capital gains; on that basis, the assessee was entitled to set off the depreciation against the addition made for unaccounted stock. The revenue's reliance on Section 79A failed because it was inserted later and applied only from 01.04.2022, and Section 115BBE(2) was also inapplicable because the assessment was not framed under that provision. The substantial questions of law were answered in favour of the assessee.
Unabsorbed depreciation carried forward under Section 32(2) retains the character of current-year loss and may be set off against business income or other income, except capital gains; on that basis, the assessee was entitled to set off the depreciation against the addition made for unaccounted stock. The revenue's reliance on Section 79A failed because it was inserted later and applied only from 01.04.2022, and Section 115BBE(2) was also inapplicable because the assessment was not framed under that provision. The substantial questions of law were answered in favour of the assessee.
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