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...
Time sought by an assessee through adjournments in proceedings under section 148A(b), including extended time, must be excluded while computing limitation under the fifth and sixth provisos to section 149. Where no reply is ultimately filed and a further adjournment request is rejected, the rejection date is treated as the deemed date of reply. On that basis, the Assessing Officer had the statutory period available thereafter, so the order under section 148A(d) and the consequential notice under section 148 issued on the next day were within limitation. The limitation challenge was rejected and the reassessment proceedings were sustained.
Time sought by an assessee through adjournments in proceedings under section 148A(b), including extended time, must be excluded while computing limitation under the fifth and sixth provisos to section 149. Where no reply is ultimately filed and a further adjournment request is rejected, the rejection date is treated as the deemed date of reply. On that basis, the Assessing Officer had the statutory period available thereafter, so the order under section 148A(d) and the consequential notice under section 148 issued on the next day were within limitation. The limitation challenge was rejected and the reassessment proceedings were sustained.
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