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...
Eligibility to act as an authorised representative is distinct from eligibility for registration as an Income Tax Practitioner. Section 515 read with Rule 252 governs who may appear as an authorised representative, while Rules 255 to 257 govern entry in the register and grant of a certificate of registration. The one-year practice requirement in Rule 257 applies only to registration; it does not restrict the separate right to appear as a representative. As the applicant had not completed one year's practice on the date of application, and the rule itself was not challenged, the return of the application was held lawful and a fresh application was permitted after completion of the prescribed period.
Eligibility to act as an authorised representative is distinct from eligibility for registration as an Income Tax Practitioner. Section 515 read with Rule 252 governs who may appear as an authorised representative, while Rules 255 to 257 govern entry in the register and grant of a certificate of registration. The one-year practice requirement in Rule 257 applies only to registration; it does not restrict the separate right to appear as a representative. As the applicant had not completed one year's practice on the date of application, and the rule itself was not challenged, the return of the application was held lawful and a fresh application was permitted after completion of the prescribed period.
Note: It is a system-generated summary and is for quick reference only.