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...
Principle of consistency required deletion of the transfer pricing adjustment on management fees because the same issue had already been decided in the assessee's favour in earlier years and no distinguishing feature was shown. The remaining issues were not decided on merits: alleged double addition arising from return processing, short grant of TDS credit, and levy of interest under section 234A with consequential interest under section 234B were all remanded to the Assessing Officer for factual verification and fresh order after hearing the assessee.
Principle of consistency required deletion of the transfer pricing adjustment on management fees because the same issue had already been decided in the assessee's favour in earlier years and no distinguishing feature was shown. The remaining issues were not decided on merits: alleged double addition arising from return processing, short grant of TDS credit, and levy of interest under section 234A with consequential interest under section 234B were all remanded to the Assessing Officer for factual verification and fresh order after hearing the assessee.
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