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...
Rule 86A(3) limits the blocking of an electronic credit ledger to one year from the date the restriction is imposed, and the restriction ceases automatically on expiry of that period. As the ledger had been blocked on 21.11.2024 and the blocking was still continuing beyond twelve months, the HC held that the continuation could not be sustained in law. The restriction was treated as having ceased by efflux of time, and the authorities were directed to unblock the electronic credit ledger forthwith.
Rule 86A(3) limits the blocking of an electronic credit ledger to one year from the date the restriction is imposed, and the restriction ceases automatically on expiry of that period. As the ledger had been blocked on 21.11.2024 and the blocking was still continuing beyond twelve months, the HC held that the continuation could not be sustained in law. The restriction was treated as having ceased by efflux of time, and the authorities were directed to unblock the electronic credit ledger forthwith.
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