Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
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...
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TNMM comparability must remain functionally robust: several software service comparables were excluded for lack of functional similarity, aggregate related-party transaction filtering was required for all selected comparables, and certain companies were restored for fresh FAR analysis or year-end data review. Working capital adjustment was restored because comparable margins must be adjusted for material profit-affecting differences; risk adjustment was refused for lack of demonstrated quantification, and delayed receivables were to be recomputed after giving effect to the final working capital adjustment. The mark-up on reimbursements was deleted for lack of factual and legal basis, interest income on the loan was remanded for fresh real-income examination, prepaid tax credit on amalgamation was to be verified and granted where corresponding income was offered, and penalty initiation was held premature.
TNMM comparability must remain functionally robust: several software service comparables were excluded for lack of functional similarity, aggregate related-party transaction filtering was required for all selected comparables, and certain companies were restored for fresh FAR analysis or year-end data review. Working capital adjustment was restored because comparable margins must be adjusted for material profit-affecting differences; risk adjustment was refused for lack of demonstrated quantification, and delayed receivables were to be recomputed after giving effect to the final working capital adjustment. The mark-up on reimbursements was deleted for lack of factual and legal basis, interest income on the loan was remanded for fresh real-income examination, prepaid tax credit on amalgamation was to be verified and granted where corresponding income was offered, and penalty initiation was held premature.
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