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...
HC held that no error apparent on the face of the record was shown in the earlier order directing consideration of the assessee's pending rectification application and quashing the revised Form-2 under the DTVSV Scheme. The Court noted that the earlier order had already considered the material chronology, including the declaration, initial Form-2, pending rectification request, and the later revised Form-2 issued while the departmental appeal was still pending. Omission to refer to Circular No. 19/2024 did not justify review, because review cannot be used to reopen or reargue issues already decided. The petition was therefore an impermissible attempt at rehearing on merits and was dismissed.
HC held that no error apparent on the face of the record was shown in the earlier order directing consideration of the assessee's pending rectification application and quashing the revised Form-2 under the DTVSV Scheme. The Court noted that the earlier order had already considered the material chronology, including the declaration, initial Form-2, pending rectification request, and the later revised Form-2 issued while the departmental appeal was still pending. Omission to refer to Circular No. 19/2024 did not justify review, because review cannot be used to reopen or reargue issues already decided. The petition was therefore an impermissible attempt at rehearing on merits and was dismissed.
Note: It is a system-generated summary and is for quick reference only.