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...
An appellate authority can entertain an alternate deduction claim even without a revised return where the claim is not a fresh item but a request to allow the same interest expenditure under the correct head, and the issue can be examined on existing material. The Tribunal rejected the Revenue's objection based on non-filing of a revised return and upheld admission of the claim in appeal. It also held that interest on borrowed funds remained deductible as business expenditure because the loan had been used for business and that factual finding was not displaced. The disallowance was therefore unsustainable and the Revenue's appeals failed.
An appellate authority can entertain an alternate deduction claim even without a revised return where the claim is not a fresh item but a request to allow the same interest expenditure under the correct head, and the issue can be examined on existing material. The Tribunal rejected the Revenue's objection based on non-filing of a revised return and upheld admission of the claim in appeal. It also held that interest on borrowed funds remained deductible as business expenditure because the loan had been used for business and that factual finding was not displaced. The disallowance was therefore unsustainable and the Revenue's appeals failed.
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