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...
A writ petition challenging an adjudication order was not examined on merits because an efficacious statutory appeal was available and the limitation period for filing that appeal was still running. The HC sustained the preliminary objection, held that the petitioner's grounds could be tested before the appellate authority, and disposed of the petition without expressing any view on the merits. All issues were left open for consideration in appeal, and the petitioner was permitted to pursue the statutory appellate remedy within the time granted.
A writ petition challenging an adjudication order was not examined on merits because an efficacious statutory appeal was available and the limitation period for filing that appeal was still running. The HC sustained the preliminary objection, held that the petitioner's grounds could be tested before the appellate authority, and disposed of the petition without expressing any view on the merits. All issues were left open for consideration in appeal, and the petitioner was permitted to pursue the statutory appellate remedy within the time granted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
