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 Section 7 application should not be rejected on maintainability without examining the real nature of the transaction where the materials disclose competing versions on whether the funds were a loan, a working-capital infusion, or a capital contribution. Entries in the corporate debtor's books showing the amount as long-term borrowing supported acknowledgment of debt, but the conflicting documents required fuller scrutiny, including the respondent's reply, before a decision on the nature of the debt could be made. The matter was therefore remanded for fresh consideration on merits, and capital contributions by directors or promoters were noted not to be retrospectively treated as financial debt without proper proof.
A Section 7 application should not be rejected on maintainability without examining the real nature of the transaction where the materials disclose competing versions on whether the funds were a loan, a working-capital infusion, or a capital contribution. Entries in the corporate debtor's books showing the amount as long-term borrowing supported acknowledgment of debt, but the conflicting documents required fuller scrutiny, including the respondent's reply, before a decision on the nature of the debt could be made. The matter was therefore remanded for fresh consideration on merits, and capital contributions by directors or promoters were noted not to be retrospectively treated as financial debt without proper proof.
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