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...
Prior-period expenditure may be considered for the correct assessment year where its genuineness is undisputed and the surrounding circumstances support the claim. The text notes that the expenditure was not disputed by the revenue and, because the assessee was a public company, the court directed that the claim be examined for AY 2003-04 if a revised computation was filed within the stated time. The operative effect is that the assessee was permitted to seek consideration of the expenditure in the appropriate year, rather than having the claim rejected on the basis of timing alone.
Prior-period expenditure may be considered for the correct assessment year where its genuineness is undisputed and the surrounding circumstances support the claim. The text notes that the expenditure was not disputed by the revenue and, because the assessee was a public company, the court directed that the claim be examined for AY 2003-04 if a revised computation was filed within the stated time. The operative effect is that the assessee was permitted to seek consideration of the expenditure in the appropriate year, rather than having the claim rejected on the basis of timing alone.
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