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...
Proceedings under Section 148A cannot be initiated against a deceased assessee; where the assessee has died, the Department must invoke the statutory mechanism under Section 159 against the legal representatives. As that route was not followed here, the notices were unsustainable and were quashed, while liberty was preserved for the Department to proceed in accordance with law against the legal representatives.
Proceedings under Section 148A cannot be initiated against a deceased assessee; where the assessee has died, the Department must invoke the statutory mechanism under Section 159 against the legal representatives. As that route was not followed here, the notices were unsustainable and were quashed, while liberty was preserved for the Department to proceed in accordance with law against the legal representatives.
Note: It is a system-generated summary and is for quick reference only.