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...
Actuarial provisions for employee benefits were treated as ascertained liabilities where the scheme existed and valuation was independently supported by actuarial assumptions, so the Bhavishya Kalyan Yojana provision was allowable under section 37(1) on the net claim revised by the assessee. The Tribunal also allowed the additional deduction for the Medicare Scheme actuarial loss disclosed in Other Comprehensive Income, because the facts were already on record and it related to the same employee benefit obligation. For salary and other expense provisions, disallowance for alleged non-deduction of tax at source was largely deleted where tax had been deducted under section 192 or no deduction was required; residual items were remanded for verification.
Actuarial provisions for employee benefits were treated as ascertained liabilities where the scheme existed and valuation was independently supported by actuarial assumptions, so the Bhavishya Kalyan Yojana provision was allowable under section 37(1) on the net claim revised by the assessee. The Tribunal also allowed the additional deduction for the Medicare Scheme actuarial loss disclosed in Other Comprehensive Income, because the facts were already on record and it related to the same employee benefit obligation. For salary and other expense provisions, disallowance for alleged non-deduction of tax at source was largely deleted where tax had been deducted under section 192 or no deduction was required; residual items were remanded for verification.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4807 
Join Channel 
