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...
Provisional attachment of the motor vehicle was confirmed because the money trail linked its purchase to compensation arising from land earlier acquired in the name of the benamidar with funds provided by the alleged beneficial owner. The Tribunal relied on the admitted employment relationship, the benamidar's sworn admission that the land had been purchased in his name by the beneficial owner, the absence of any proved independent source of funds, and recovery of the vehicle registration document from the beneficial owner. On these facts, the claim that the vehicle was bought from the benamidar's own funds was rejected, and the challenge to its benami character failed.
Provisional attachment of the motor vehicle was confirmed because the money trail linked its purchase to compensation arising from land earlier acquired in the name of the benamidar with funds provided by the alleged beneficial owner. The Tribunal relied on the admitted employment relationship, the benamidar's sworn admission that the land had been purchased in his name by the beneficial owner, the absence of any proved independent source of funds, and recovery of the vehicle registration document from the beneficial owner. On these facts, the claim that the vehicle was bought from the benamidar's own funds was rejected, and the challenge to its benami character failed.
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