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...
VCES declaration rejection could not be sustained where the notice proposing rejection was issued beyond the prescribed thirty-day period, including when measured from the circular clarifying its application to declarations already filed. The Tribunal noted that the department's reliance on general correspondence indicated only a roving inquiry, not a proper basis for rejection. As the department was bound by its own circulars, the order upholding rejection of the declaration under the Voluntary Compliance Encouragement Scheme, 2013 was set aside and the appeal was allowed with consequential relief.
VCES declaration rejection could not be sustained where the notice proposing rejection was issued beyond the prescribed thirty-day period, including when measured from the circular clarifying its application to declarations already filed. The Tribunal noted that the department's reliance on general correspondence indicated only a roving inquiry, not a proper basis for rejection. As the department was bound by its own circulars, the order upholding rejection of the declaration under the Voluntary Compliance Encouragement Scheme, 2013 was set aside and the appeal was allowed with consequential relief.
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