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...
CBDT has prescribed compulsory complete-scrutiny selection parameters for FY 2026-27, including survey cases conducted on or after 1.4.2024, search or requisition cases initiated on or after 1.4.2024, specified reopened cases under notice u/s 148, cases involving cancelled or ungranted registration/approval with exemption claims in ITR-7, recurring issues where prior additions have attained finality or been upheld for Revenue beyond the prescribed thresholds, and cases supported by specific tax-evasion information from law-enforcement or regulatory agencies. The guidelines also set out the selection and transfer procedure, including service of notice u/s 143(2), upload of supporting documents, handling of International Taxation and Central Charge cases, and a 30.6.2026 time limit for service of notice for ITRs filed in FY 2025-26.
CBDT has prescribed compulsory complete-scrutiny selection parameters for FY 2026-27, including survey cases conducted on or after 1.4.2024, search or requisition cases initiated on or after 1.4.2024, specified reopened cases under notice u/s 148, cases involving cancelled or ungranted registration/approval with exemption claims in ITR-7, recurring issues where prior additions have attained finality or been upheld for Revenue beyond the prescribed thresholds, and cases supported by specific tax-evasion information from law-enforcement or regulatory agencies. The guidelines also set out the selection and transfer procedure, including service of notice u/s 143(2), upload of supporting documents, handling of International Taxation and Central Charge cases, and a 30.6.2026 time limit for service of notice for ITRs filed in FY 2025-26.
Note: It is a system-generated summary and is for quick reference only.