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 10AA was denied where the assessee's own Form 56F and audit report showed nil export proceeds in convertible foreign exchange, and supplies to DTA or another SEZ were treated as non-qualifying absent proof of export out of India. Employees' PF and ESI contribution was disallowed because payment was made even beyond the EPFO grace period. Sundry balances written off failed for lack of supporting evidence. Bad debts written off were allowed once the amounts were recorded as irrecoverable in the accounts under TRF Ltd. Adjustment of patent-related liability against an investment was held not to attract section 41(1) because it was a capital asset transaction, not a trading liability. The section 10AA claim for AY 2018-19 was remanded for fresh verification of revised Form 56F.
Deduction under section 10AA was denied where the assessee's own Form 56F and audit report showed nil export proceeds in convertible foreign exchange, and supplies to DTA or another SEZ were treated as non-qualifying absent proof of export out of India. Employees' PF and ESI contribution was disallowed because payment was made even beyond the EPFO grace period. Sundry balances written off failed for lack of supporting evidence. Bad debts written off were allowed once the amounts were recorded as irrecoverable in the accounts under TRF Ltd. Adjustment of patent-related liability against an investment was held not to attract section 41(1) because it was a capital asset transaction, not a trading liability. The section 10AA claim for AY 2018-19 was remanded for fresh verification of revised Form 56F.
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