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 accumulated amount claimed as exempt under section 11(2) in AY 2012-13 could not be re-claimed as exempt in AY 2017-18 when the assessee had already obtained exemption for that accumulation and no material showed otherwise. The Tribunal treated the fresh claim as a double exemption. It also found, on the assessee's accounts and Form 10B, that the current year's income met the year's expenditure, while the disputed accumulated amount was not applied and remained in reserves. As the accumulation stayed unutilised until expiry of the permitted period, section 11(3) applied and the balance became deemed income. The Revenue's appeal was allowed and the addition was restored.
An accumulated amount claimed as exempt under section 11(2) in AY 2012-13 could not be re-claimed as exempt in AY 2017-18 when the assessee had already obtained exemption for that accumulation and no material showed otherwise. The Tribunal treated the fresh claim as a double exemption. It also found, on the assessee's accounts and Form 10B, that the current year's income met the year's expenditure, while the disputed accumulated amount was not applied and remained in reserves. As the accumulation stayed unutilised until expiry of the permitted period, section 11(3) applied and the balance became deemed income. The Revenue's appeal was allowed and the addition was restored.
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