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...
Section 53A of the Transfer of Property Act did not confer ownership for depreciation where there was no written and registered transfer instrument, so the assessee could not treat the properties as firm assets or claim depreciation on that basis. The assessment was also not vitiated by natural justice grounds because the show-cause process and repeated notices already covered the relevant factual basis, and the shift from unexplained investment to unexplained credit was treated as a consequence of the same inquiry. Having rejected the jurisdictional and procedural objections, the Court declined to examine the merits of the unexplained credit dispute in writ jurisdiction and relegated the assessee to the statutory appellate remedy.
Section 53A of the Transfer of Property Act did not confer ownership for depreciation where there was no written and registered transfer instrument, so the assessee could not treat the properties as firm assets or claim depreciation on that basis. The assessment was also not vitiated by natural justice grounds because the show-cause process and repeated notices already covered the relevant factual basis, and the shift from unexplained investment to unexplained credit was treated as a consequence of the same inquiry. Having rejected the jurisdictional and procedural objections, the Court declined to examine the merits of the unexplained credit dispute in writ jurisdiction and relegated the assessee to the statutory appellate remedy.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
