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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Goodwill arising from amalgamation of a running business was treated as a depreciable intangible asset because it represented commercial rights covered by the depreciation provision, and the Tribunal followed its earlier years' view in the absence of any change in facts or law. The deletion of disallowance of depreciation on goodwill was upheld. For captive power transfers, the Tribunal accepted the internal CUP benchmark based on the consumer tariff charged by the distribution company for valuing inter-unit electricity sales, holding that regulatory tariff was not the proper market benchmark. On that basis, the transfer pricing adjustment affecting the section 80IA deduction was deleted and the assessee's claim was sustained.
Goodwill arising from amalgamation of a running business was treated as a depreciable intangible asset because it represented commercial rights covered by the depreciation provision, and the Tribunal followed its earlier years' view in the absence of any change in facts or law. The deletion of disallowance of depreciation on goodwill was upheld. For captive power transfers, the Tribunal accepted the internal CUP benchmark based on the consumer tariff charged by the distribution company for valuing inter-unit electricity sales, holding that regulatory tariff was not the proper market benchmark. On that basis, the transfer pricing adjustment affecting the section 80IA deduction was deleted and the assessee's claim was sustained.
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