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...
Disallowance under section 14A cannot exceed the exempt income earned in the relevant year, so a higher Rule 8D disallowance was not sustainable where the assessee had already made a suo motu disallowance. The Tribunal upheld restriction of the disallowance to the amount already offered by the assessee. On CSR-related donations, it held that Explanation 2 to section 37(1) only denies CSR expenditure as business deduction and does not bar a separate deduction under section 80G if the statutory conditions are met. Approved donee status and banking-channel payments supported the claim, so the deduction was upheld.
Disallowance under section 14A cannot exceed the exempt income earned in the relevant year, so a higher Rule 8D disallowance was not sustainable where the assessee had already made a suo motu disallowance. The Tribunal upheld restriction of the disallowance to the amount already offered by the assessee. On CSR-related donations, it held that Explanation 2 to section 37(1) only denies CSR expenditure as business deduction and does not bar a separate deduction under section 80G if the statutory conditions are met. Approved donee status and banking-channel payments supported the claim, so the deduction was upheld.
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