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...
TDS credit cannot be denied in scrutiny assessment where the Revenue had already rectified the earlier intimation and granted the credit, leaving no surviving dispute on the same claim. The Tribunal held that the Assessing Officer overlooked the rectification order and that, in the absence of any asserted mismatch, deficiency in the claim, or failure to offer the corresponding income, the assessee remained entitled to the tax credit actually prepaid by TDS. The consequential interest levied under sections 234A and 234B was therefore deleted.
TDS credit cannot be denied in scrutiny assessment where the Revenue had already rectified the earlier intimation and granted the credit, leaving no surviving dispute on the same claim. The Tribunal held that the Assessing Officer overlooked the rectification order and that, in the absence of any asserted mismatch, deficiency in the claim, or failure to offer the corresponding income, the assessee remained entitled to the tax credit actually prepaid by TDS. The consequential interest levied under sections 234A and 234B was therefore deleted.
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