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...
Accumulation under section 11(2) could not be denied where the trust filed Form No. 10 within time, the stated purpose of repair, renovation and maintenance of temple-related premises fell within the trust's religious and charitable objects, and the accumulated funds were invested in fixed deposits with HDFC Bank, a permissible mode under section 11(5). Minor variations or general descriptions in Form No. 10 were held insufficient by themselves to defeat the benefit. Only the limited factual issue of verifying the dates of investment was remanded to the Assessing Officer for examination and consequential relief in accordance with law.
Accumulation under section 11(2) could not be denied where the trust filed Form No. 10 within time, the stated purpose of repair, renovation and maintenance of temple-related premises fell within the trust's religious and charitable objects, and the accumulated funds were invested in fixed deposits with HDFC Bank, a permissible mode under section 11(5). Minor variations or general descriptions in Form No. 10 were held insufficient by themselves to defeat the benefit. Only the limited factual issue of verifying the dates of investment was remanded to the Assessing Officer for examination and consequential relief in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4823 
Join Channel 
