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...
Faceless reassessment under the IT Act was challenged on the ground that the notice under section 148 had to be issued by the Faceless Assessing Officer and not the jurisdictional officer for alleged non-compliance with section 151A. Without deciding that merits question, the Court directed revival of the pending appeal before the Commissioner (Appeals), permitted the petitioner to raise all grounds including limitation, stayed operation of the assessment order during the appeal, and ordered expeditious disposal.
Faceless reassessment under the IT Act was challenged on the ground that the notice under section 148 had to be issued by the Faceless Assessing Officer and not the jurisdictional officer for alleged non-compliance with section 151A. Without deciding that merits question, the Court directed revival of the pending appeal before the Commissioner (Appeals), permitted the petitioner to raise all grounds including limitation, stayed operation of the assessment order during the appeal, and ordered expeditious disposal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
