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 pure legal challenge to a reassessment notice was admitted in cross objection because it went to the root of jurisdiction and had already been raised below. On merits, the ITAT held that a reopening notice issued beyond six years from the end of the relevant assessment year was time-barred. Applying the jurisdictional High Court view, it ruled that the extended reassessment limitation under the amended law operates prospectively and does not revive cases where the old six-year period had already expired. The notice was quashed, the reassessment was invalidated, the assessee's cross objection was allowed, and the Revenue's appeal on merits failed.
A pure legal challenge to a reassessment notice was admitted in cross objection because it went to the root of jurisdiction and had already been raised below. On merits, the ITAT held that a reopening notice issued beyond six years from the end of the relevant assessment year was time-barred. Applying the jurisdictional High Court view, it ruled that the extended reassessment limitation under the amended law operates prospectively and does not revive cases where the old six-year period had already expired. The notice was quashed, the reassessment was invalidated, the assessee's cross objection was allowed, and the Revenue's appeal on merits failed.
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