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...
The Tribunal dealt with three business expenditure claims. It deleted disallowance of input tax credit reversal because the amount was shown to form part of total project cost and was apportioned between cost of sales and closing work-in-progress, so the factual basis for rejection failed. It remanded the claim for advances written off as trading loss because the assessee had to first establish business purpose and irrecoverability, and was allowed to produce further evidence. It sustained disallowance of social activity and charitable expenditure, holding that charitable outlays and an unexplained training fee had no demonstrated nexus with the real estate business.
The Tribunal dealt with three business expenditure claims. It deleted disallowance of input tax credit reversal because the amount was shown to form part of total project cost and was apportioned between cost of sales and closing work-in-progress, so the factual basis for rejection failed. It remanded the claim for advances written off as trading loss because the assessee had to first establish business purpose and irrecoverability, and was allowed to produce further evidence. It sustained disallowance of social activity and charitable expenditure, holding that charitable outlays and an unexplained training fee had no demonstrated nexus with the real estate business.
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