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 single show-cause notice or composite GST assessment cannot validly cover more than one tax period; where assessment is taken before the annual return due date, the bar applies beyond one month, and after that due date, beyond one year. The assessment and appellate orders were set aside because the challenge was confined to the impermissible clubbing of multiple assessment years. Authorities were left free to start fresh proceedings separately for each assessment year, and the intervening period was directed to be excluded while computing limitation.
A single show-cause notice or composite GST assessment cannot validly cover more than one tax period; where assessment is taken before the annual return due date, the bar applies beyond one month, and after that due date, beyond one year. The assessment and appellate orders were set aside because the challenge was confined to the impermissible clubbing of multiple assessment years. Authorities were left free to start fresh proceedings separately for each assessment year, and the intervening period was directed to be excluded while computing limitation.
Note: It is a system-generated summary and is for quick reference only.