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...
Rectification is available for a mistake apparent from the record, and the record is not confined to the assessment order or intimation alone. A wrong entry in the return showing mutual fund units as acquired on or after 31.01.2018 could be corrected where supporting material in the assessee's record showed acquisition before that date. The authorities were not justified in refusing rectification merely because the correction would alter total income. The matter was restored for verification of the evidence and recomputation of long-term capital gains on the basis that the units were acquired prior to 31.01.2018.
Rectification is available for a mistake apparent from the record, and the record is not confined to the assessment order or intimation alone. A wrong entry in the return showing mutual fund units as acquired on or after 31.01.2018 could be corrected where supporting material in the assessee's record showed acquisition before that date. The authorities were not justified in refusing rectification merely because the correction would alter total income. The matter was restored for verification of the evidence and recomputation of long-term capital gains on the basis that the units were acquired prior to 31.01.2018.
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