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...
Faceless reassessment under section 147 read with section 144B was treated as a best judgment reassessment where the assessee did not comply with section 142(1) notices and did not properly respond to section 144 show-cause notices. On that footing, the proviso to section 251(1)(a), effective from 01.10.2024, permitted the appellate authority to set aside the assessment and remand it for fresh adjudication. The remand was upheld because the assessing officer had not verified the material and additional evidence had been filed in appeal, making de novo assessment with opportunity to the assessee justified. The Revenue's objection was rejected and the reassessment was sent back for fresh disposal.
Faceless reassessment under section 147 read with section 144B was treated as a best judgment reassessment where the assessee did not comply with section 142(1) notices and did not properly respond to section 144 show-cause notices. On that footing, the proviso to section 251(1)(a), effective from 01.10.2024, permitted the appellate authority to set aside the assessment and remand it for fresh adjudication. The remand was upheld because the assessing officer had not verified the material and additional evidence had been filed in appeal, making de novo assessment with opportunity to the assessee justified. The Revenue's objection was rejected and the reassessment was sent back for fresh disposal.
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