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...
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Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Interest on borrowed capital was held deductible as revenue expenditure because the Tribunal's binding factual finding showed the investments in subsidiary or joint venture concerns were made for business expansion and commercial expediency in the assessee's fertilizer business. The Revenue's contrary view was rejected, and the later remand on actual use of borrowed funds was treated as academic in light of that finding. On rectification, the Court held that a prior liberty to move the Tribunal did not oblige it to allow rectification; no mistake apparent from the record was shown, so dismissal of the miscellaneous petition was proper. The appeal was dismissed.
Interest on borrowed capital was held deductible as revenue expenditure because the Tribunal's binding factual finding showed the investments in subsidiary or joint venture concerns were made for business expansion and commercial expediency in the assessee's fertilizer business. The Revenue's contrary view was rejected, and the later remand on actual use of borrowed funds was treated as academic in light of that finding. On rectification, the Court held that a prior liberty to move the Tribunal did not oblige it to allow rectification; no mistake apparent from the record was shown, so dismissal of the miscellaneous petition was proper. The appeal was dismissed.
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