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...
Turnover is a relevant comparability factor in transfer pricing because scale affects profitability, risk and economies of scale; disproportionately large software companies were therefore excluded, while judicial discipline and the doctrine of merger required following the jurisdictional High Court view. Companies lacking reliable segmental data, showing mixed product and service activities, or failing employee cost and service revenue filters were treated as unsuitable comparables. By the same functional test, a software services company with support from its annual report was included. In the marketing support segment, an indenting and trading entity was excluded, while an advertising agency was included because advertising and marketing support operate in the same promotional domain.
Turnover is a relevant comparability factor in transfer pricing because scale affects profitability, risk and economies of scale; disproportionately large software companies were therefore excluded, while judicial discipline and the doctrine of merger required following the jurisdictional High Court view. Companies lacking reliable segmental data, showing mixed product and service activities, or failing employee cost and service revenue filters were treated as unsuitable comparables. By the same functional test, a software services company with support from its annual report was included. In the marketing support segment, an indenting and trading entity was excluded, while an advertising agency was included because advertising and marketing support operate in the same promotional domain.
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