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...
Retrospectively amended Section 115JA was applied to treat amounts set aside for bad and doubtful debts as a provision for diminution in the value of an asset, so the addition in book profit computation was upheld and the assessee's challenge failed. By contrast, the audit report requirement for a deduction claim under Section 80IA(7) was treated as directory for the relevant period, so failure to file it before assessment did not defeat the claim when the report was produced before the appellate authority. The appeal was therefore partly allowed, with the Revenue succeeding on book profit treatment and the assessee succeeding on the audit-report issue.
Retrospectively amended Section 115JA was applied to treat amounts set aside for bad and doubtful debts as a provision for diminution in the value of an asset, so the addition in book profit computation was upheld and the assessee's challenge failed. By contrast, the audit report requirement for a deduction claim under Section 80IA(7) was treated as directory for the relevant period, so failure to file it before assessment did not defeat the claim when the report was produced before the appellate authority. The appeal was therefore partly allowed, with the Revenue succeeding on book profit treatment and the assessee succeeding on the audit-report issue.
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