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 11 of the Black Money Act required completion of assessment within two years from the end of the financial year in which notice under section 10(1) was issued, so a notice dated 10-04-2018 meant the assessment had to be completed by 31-03-2021 unless a valid exclusion applied. The exchange-of-information exclusion did not apply because the relevant FT & TR references had already been made and the information received before proceedings began. TOLA and Notification No. 113/2021 did not save the delay, as that notification extended time only for the Income-tax Act and the Benami Transactions Act. The assessment order passed on 17-02-2022 was therefore quashed as time-barred.
Section 11 of the Black Money Act required completion of assessment within two years from the end of the financial year in which notice under section 10(1) was issued, so a notice dated 10-04-2018 meant the assessment had to be completed by 31-03-2021 unless a valid exclusion applied. The exchange-of-information exclusion did not apply because the relevant FT & TR references had already been made and the information received before proceedings began. TOLA and Notification No. 113/2021 did not save the delay, as that notification extended time only for the Income-tax Act and the Benami Transactions Act. The assessment order passed on 17-02-2022 was therefore quashed as time-barred.
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