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...
Corporate guarantee commission was allocated only in part where the guarantee to the foreign associated enterprise's lenders was jointly furnished by the assessee and its subsidiary; on that basis, only 0.25% was attributable to the assessee. Interest disallowance on borrowed capital was not sustained for non-interest-bearing advances to AAIPL because the advances were made in the course of the real estate business and the decision to waive interest was commercially expedient to protect business interests and principal exposure. The same commercial expediency principle applied to advances to SCA LLP after the assessee became the majority partner with management control, making the funding commercially driven and not a basis for disallowing corresponding interest.
Corporate guarantee commission was allocated only in part where the guarantee to the foreign associated enterprise's lenders was jointly furnished by the assessee and its subsidiary; on that basis, only 0.25% was attributable to the assessee. Interest disallowance on borrowed capital was not sustained for non-interest-bearing advances to AAIPL because the advances were made in the course of the real estate business and the decision to waive interest was commercially expedient to protect business interests and principal exposure. The same commercial expediency principle applied to advances to SCA LLP after the assessee became the majority partner with management control, making the funding commercially driven and not a basis for disallowing corresponding interest.
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