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...
A resident individual under the new tax regime was held entitled to rebate under section 87A even though part of the income was short-term capital gains taxed under section 111A, because neither section 87A nor section 111A contained an express exclusion for such income in the relevant assessment year. The Tribunal applied earlier coordinate-bench rulings, reasoning that the new-regime provision governs tax computation while the rebate continues to apply to the tax so computed unless specifically barred by law. As the Revenue showed no change in facts or law and no contrary material, the disallowance of rebate was deleted for AY 2024-25.
A resident individual under the new tax regime was held entitled to rebate under section 87A even though part of the income was short-term capital gains taxed under section 111A, because neither section 87A nor section 111A contained an express exclusion for such income in the relevant assessment year. The Tribunal applied earlier coordinate-bench rulings, reasoning that the new-regime provision governs tax computation while the rebate continues to apply to the tax so computed unless specifically barred by law. As the Revenue showed no change in facts or law and no contrary material, the disallowance of rebate was deleted for AY 2024-25.
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