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...
Income declared under the IDS-2016 became chargeable to tax under the Income-tax Act in the previous year in which the declaration was made when the declarant failed to pay the tax, surcharge and penalty within the prescribed time. As the declaration was filed on 28.09.2016, the Tribunal held that the Revenue could not reopen and assess that amount in AY 2013-14. The reassessment and corresponding addition for that year were therefore unsustainable in law, and the addition was deleted.
Income declared under the IDS-2016 became chargeable to tax under the Income-tax Act in the previous year in which the declaration was made when the declarant failed to pay the tax, surcharge and penalty within the prescribed time. As the declaration was filed on 28.09.2016, the Tribunal held that the Revenue could not reopen and assess that amount in AY 2013-14. The reassessment and corresponding addition for that year were therefore unsustainable in law, and the addition was deleted.
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