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...
A statutory maritime board was held to fall within charitable purpose as an institution advancing general public utility, because its port dues, vessel-related charges, cargo and land charges, and other user fees arose from statutory port development, regulation and allied functions under governmental control. Surplus, reserves, or private participation through concessions did not by themselves establish commercial activity, so exemption under sections 11 and 12 remained available. An impermissible investment under section 11(5) read with section 13(1)(d) was held to affect only the income relatable to the offending investment, not the entire exemption. Addition of tax deducted at source as separate income was deleted. Depreciation under section 11(6) required asset-wise factual verification where double deduction was not shown.
A statutory maritime board was held to fall within charitable purpose as an institution advancing general public utility, because its port dues, vessel-related charges, cargo and land charges, and other user fees arose from statutory port development, regulation and allied functions under governmental control. Surplus, reserves, or private participation through concessions did not by themselves establish commercial activity, so exemption under sections 11 and 12 remained available. An impermissible investment under section 11(5) read with section 13(1)(d) was held to affect only the income relatable to the offending investment, not the entire exemption. Addition of tax deducted at source as separate income was deleted. Depreciation under section 11(6) required asset-wise factual verification where double deduction was not shown.
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