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...
Disallowance under section 14A was confined to the exempt income actually earned, because the Tribunal followed the binding Delhi High Court view that such disallowance cannot exceed the exempt income. The assessee had earned exempt income, while the Assessing Officer computed a higher amount under Rule 8D; the Tribunal restricted the disallowance to the exempt income amount. It also held that the Explanation inserted in section 14A by the Finance Act, 2022 operates prospectively and did not apply to Assessment Year 2017-18. The appeal was partly allowed and the disallowance was restricted accordingly.
Disallowance under section 14A was confined to the exempt income actually earned, because the Tribunal followed the binding Delhi High Court view that such disallowance cannot exceed the exempt income. The assessee had earned exempt income, while the Assessing Officer computed a higher amount under Rule 8D; the Tribunal restricted the disallowance to the exempt income amount. It also held that the Explanation inserted in section 14A by the Finance Act, 2022 operates prospectively and did not apply to Assessment Year 2017-18. The appeal was partly allowed and the disallowance was restricted accordingly.
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