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...
Belated filing of Form 10E did not, by itself, defeat the assessee's claim for tax relief where entitlement was otherwise admissible in law. The Tribunal applied a liberal construction to the filing requirement, treating the delay as a procedural lapse that should not override substantive rights. It held that the claim had to be examined and verified by the AO/CPC once the form was on record. The impugned order was set aside and the matter remanded for verification of Form 10E and grant of relief if found admissible.
Belated filing of Form 10E did not, by itself, defeat the assessee's claim for tax relief where entitlement was otherwise admissible in law. The Tribunal applied a liberal construction to the filing requirement, treating the delay as a procedural lapse that should not override substantive rights. It held that the claim had to be examined and verified by the AO/CPC once the form was on record. The impugned order was set aside and the matter remanded for verification of Form 10E and grant of relief if found admissible.
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