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...
Site restoration expenditure was held deductible, as the Court noted that the connected appeals had already upheld the assessee's claim under Section 37(1); once that position was accepted, the Revenue's challenge to the Tribunal's view on book profit treatment also failed. The reassessment for AY 1999-2000 was also sustained as invalid: it had been initiated after four years, the assessee was not supplied the recorded reasons, no notice under Section 143(2) was served, and the Department failed to justify reopening beyond limitation before the appellate authorities.
Site restoration expenditure was held deductible, as the Court noted that the connected appeals had already upheld the assessee's claim under Section 37(1); once that position was accepted, the Revenue's challenge to the Tribunal's view on book profit treatment also failed. The reassessment for AY 1999-2000 was also sustained as invalid: it had been initiated after four years, the assessee was not supplied the recorded reasons, no notice under Section 143(2) was served, and the Department failed to justify reopening beyond limitation before the appellate authorities.
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