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...
Immediate instructions require all groups to prepare detailed, updated briefs for every matter pending before the Supreme Court, with cases graded for monitoring, including constitutional challenges and high-revenue matters. Files and synopses must be properly indexed and kept immediately retrievable so briefing can be provided to the Learned ASG at short notice. At least two to three senior officers in each group, including the Assistant Commissioner and the JC/ADC concerned, must familiarise themselves with case details to ensure effective briefing. The Deputy/Assistant Commissioner of each group is made responsible for monitoring strict compliance with these directions.
Immediate instructions require all groups to prepare detailed, updated briefs for every matter pending before the Supreme Court, with cases graded for monitoring, including constitutional challenges and high-revenue matters. Files and synopses must be properly indexed and kept immediately retrievable so briefing can be provided to the Learned ASG at short notice. At least two to three senior officers in each group, including the Assistant Commissioner and the JC/ADC concerned, must familiarise themselves with case details to ensure effective briefing. The Deputy/Assistant Commissioner of each group is made responsible for monitoring strict compliance with these directions.
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