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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
TNMM was accepted for intra-group management fees and technology and trademark licence fees because the same transactions had been treated as interlinked in earlier and subsequent years, with no change in functions, assets or risks shown and evidence of services and business benefit on record; the CUP-based nil valuation was therefore unsustainable and the transfer pricing adjustments were deleted. SAP implementation cost was also treated as a reasonable, scientific allocation for IT support services because the services were used daily, billed by actual user headcount, and the need and rendition tests were satisfied; the nil ALP adjustment was deleted. The disallowance of employees' contribution to Provident Fund and ESIC was sustained under the Supreme Court ruling in Checkmate Service Private Limited.
TNMM was accepted for intra-group management fees and technology and trademark licence fees because the same transactions had been treated as interlinked in earlier and subsequent years, with no change in functions, assets or risks shown and evidence of services and business benefit on record; the CUP-based nil valuation was therefore unsustainable and the transfer pricing adjustments were deleted. SAP implementation cost was also treated as a reasonable, scientific allocation for IT support services because the services were used daily, billed by actual user headcount, and the need and rendition tests were satisfied; the nil ALP adjustment was deleted. The disallowance of employees' contribution to Provident Fund and ESIC was sustained under the Supreme Court ruling in Checkmate Service Private Limited.
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