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...
The Tribunal held that the extended reassessment period beyond three years was unavailable because the alleged escaped income related only to a claimed donation deduction and did not meet the statutory monetary threshold for extension. It further found that, even after excluding the time allowed to respond to the section 148A(b) notice, the Assessing Officer had time only until 07/04/2023 to issue the reassessment notice, but it was issued on 10/04/2023. The sixth proviso was therefore inapplicable, and the reassessment notice was time-barred and invalid; the merits of the disallowance were left open.
The Tribunal held that the extended reassessment period beyond three years was unavailable because the alleged escaped income related only to a claimed donation deduction and did not meet the statutory monetary threshold for extension. It further found that, even after excluding the time allowed to respond to the section 148A(b) notice, the Assessing Officer had time only until 07/04/2023 to issue the reassessment notice, but it was issued on 10/04/2023. The sixth proviso was therefore inapplicable, and the reassessment notice was time-barred and invalid; the merits of the disallowance were left open.
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