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...
Finality barred reopening of transfers and acquisitions already examined by a court-approved SIT; later foreign material, media reports and digital fragments were treated as insufficient grounds for fresh investigation, prosecution or coercive action. The Court also noted that zoological acquisitions supported by valid domestic permission and CITES compliance may not be invalidated merely because the foreign source was described as commercial, with the purpose code issue not being decisive except for Appendix I specimens. Requests to compel insiders while insulating them from confidentiality consequences were rejected. Prospectively, the Court directed the CITES Management Authority of India to strengthen import-permit due diligence through liaison with the CITES Secretariat and an SOP for Appendix I imports.
Finality barred reopening of transfers and acquisitions already examined by a court-approved SIT; later foreign material, media reports and digital fragments were treated as insufficient grounds for fresh investigation, prosecution or coercive action. The Court also noted that zoological acquisitions supported by valid domestic permission and CITES compliance may not be invalidated merely because the foreign source was described as commercial, with the purpose code issue not being decisive except for Appendix I specimens. Requests to compel insiders while insulating them from confidentiality consequences were rejected. Prospectively, the Court directed the CITES Management Authority of India to strengthen import-permit due diligence through liaison with the CITES Secretariat and an SOP for Appendix I imports.
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