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 seeking a creamy-layer based restriction on scheduled tribe tax exemption was treated as a request to alter legislative public policy, and the SC declined to entertain it in constitutional writ jurisdiction. The Court held that prayers to formulate, revise, or amend the exemption policy were not appropriate for adjudication at that stage. It left the petitioner free to pursue the matter before the Committee on Petitions and to forward the petition as a representation to the concerned authorities.
A writ petition seeking a creamy-layer based restriction on scheduled tribe tax exemption was treated as a request to alter legislative public policy, and the SC declined to entertain it in constitutional writ jurisdiction. The Court held that prayers to formulate, revise, or amend the exemption policy were not appropriate for adjudication at that stage. It left the petitioner free to pursue the matter before the Committee on Petitions and to forward the petition as a representation to the concerned authorities.
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