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...
Deduction under section 80G was allowed for donations forming part of CSR expenditure because disallowance under Explanation 2 to section 37(1) did not itself bar the section 80G claim. The enhanced deduction claim under section 80-IA was not decided on merits and was remanded to the AO for verification of revised evidence and supporting material. On the transfer pricing issue, working capital adjustment was directed to be granted while re-examining receivables from associated enterprises. Computation of income, section 80M deduction, and interest under sections 244A and 234C were also restored for fresh consideration, and the challenge to penalty initiation was dismissed as premature. The appeal was partly allowed.
Deduction under section 80G was allowed for donations forming part of CSR expenditure because disallowance under Explanation 2 to section 37(1) did not itself bar the section 80G claim. The enhanced deduction claim under section 80-IA was not decided on merits and was remanded to the AO for verification of revised evidence and supporting material. On the transfer pricing issue, working capital adjustment was directed to be granted while re-examining receivables from associated enterprises. Computation of income, section 80M deduction, and interest under sections 244A and 234C were also restored for fresh consideration, and the challenge to penalty initiation was dismissed as premature. The appeal was partly allowed.
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