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...
Taxability of distribution fee earned for granting BBC News Channel distribution rights was not decided on merits, as the assessee had raised a fresh claim before the appellate stage after originally offering the amount to tax. Taking note of the CBDT circular that only legitimate tax should be assessed and collected, the ITAT restored the matter to the Jurisdictional Assessing Officer for de novo consideration on merits, with due opportunity of hearing to the assessee. The appeal was allowed for statistical purposes, and the question of tax liability remained open.
Taxability of distribution fee earned for granting BBC News Channel distribution rights was not decided on merits, as the assessee had raised a fresh claim before the appellate stage after originally offering the amount to tax. Taking note of the CBDT circular that only legitimate tax should be assessed and collected, the ITAT restored the matter to the Jurisdictional Assessing Officer for de novo consideration on merits, with due opportunity of hearing to the assessee. The appeal was allowed for statistical purposes, and the question of tax liability remained open.
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