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 reassessment based on alleged escapement of interest income could not be sustained when no addition was ultimately made on that recorded ground and the Assessing Officer instead disallowed loan processing fees, an item outside the reopening reasons. Applying Jet Airways, the Tribunal held that once the recorded basis for reopening failed, the officer could not independently assess a different issue without a fresh reopening notice. The addition was therefore deleted for want of jurisdictional foundation, and the assessee's appeal was allowed.
A reassessment based on alleged escapement of interest income could not be sustained when no addition was ultimately made on that recorded ground and the Assessing Officer instead disallowed loan processing fees, an item outside the reopening reasons. Applying Jet Airways, the Tribunal held that once the recorded basis for reopening failed, the officer could not independently assess a different issue without a fresh reopening notice. The addition was therefore deleted for want of jurisdictional foundation, and the assessee's appeal was allowed.
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