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...
Section 36(1)(viia) allows deduction only for a provision for bad and doubtful debts actually made in the bank's books and within the statutory ceiling linked to total income and average rural advances. For the years in question, the provision need not follow any separate Income-tax Act method of quantification, and RBI prudential norms govern provisioning, including a general provision on standard assets because they still carry credit risk. The earlier proviso relating to doubtful or loss assets was confined to specified earlier assessment years and did not exclude standard assets here. The Special Bench answered the reference for the assessee and held that provision on standard assets made in accordance with RBI norms qualified for deduction, subject to the books and ceiling requirements.
Section 36(1)(viia) allows deduction only for a provision for bad and doubtful debts actually made in the bank's books and within the statutory ceiling linked to total income and average rural advances. For the years in question, the provision need not follow any separate Income-tax Act method of quantification, and RBI prudential norms govern provisioning, including a general provision on standard assets because they still carry credit risk. The earlier proviso relating to doubtful or loss assets was confined to specified earlier assessment years and did not exclude standard assets here. The Special Bench answered the reference for the assessee and held that provision on standard assets made in accordance with RBI norms qualified for deduction, subject to the books and ceiling requirements.
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