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...
Certified segmental financials used in transfer pricing documentation could not be rejected merely for differing from AS-17 audited segment disclosure where the assessee explained the allocation method and no specific defect was found; the issue was remitted for fresh consideration. ECB interest at LIBOR plus 3% was held to be at arm's length because the borrowing had RBI approval and the TPO made only ad hoc substitution without proper comparability analysis. Outstanding receivables from AEs were treated as an international transaction, and interest was directed to be recomputed invoice-to-invoice at LIBOR plus 200 basis points in line with earlier years. The direction to verify brought-forward amalgamation losses and allow them according to law was upheld.
Certified segmental financials used in transfer pricing documentation could not be rejected merely for differing from AS-17 audited segment disclosure where the assessee explained the allocation method and no specific defect was found; the issue was remitted for fresh consideration. ECB interest at LIBOR plus 3% was held to be at arm's length because the borrowing had RBI approval and the TPO made only ad hoc substitution without proper comparability analysis. Outstanding receivables from AEs were treated as an international transaction, and interest was directed to be recomputed invoice-to-invoice at LIBOR plus 200 basis points in line with earlier years. The direction to verify brought-forward amalgamation losses and allow them according to law was upheld.
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