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 writ petition challenging three appellate orders was found not maintainable because an efficacious statutory appeal lay before the Tribunal under the Act. The challenge centred on an alleged insistence on a notarized sale agreement, later said to have been produced, but the court held that this and the related issues required appreciation of facts and law and were therefore for the appellate forum. On that basis, writ jurisdiction was declined and the petitioners were left to pursue the statutory appellate remedy.
A writ petition challenging three appellate orders was found not maintainable because an efficacious statutory appeal lay before the Tribunal under the Act. The challenge centred on an alleged insistence on a notarized sale agreement, later said to have been produced, but the court held that this and the related issues required appreciation of facts and law and were therefore for the appellate forum. On that basis, writ jurisdiction was declined and the petitioners were left to pursue the statutory appellate remedy.
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