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...
For a non-searched person, the relevant date for determining the block period and search year under section 153C is the date on which seized material is received by the Assessing Officer having jurisdiction over that person, not the date of search in the searched person's case. On that basis, an assessment for the search-related year must be made, if at all, under section 153C read with section 153A; framing it under section 143(3) is a fatal jurisdictional defect. The impugned assessment for Assessment Year 2017-18 was therefore treated as without jurisdiction.
For a non-searched person, the relevant date for determining the block period and search year under section 153C is the date on which seized material is received by the Assessing Officer having jurisdiction over that person, not the date of search in the searched person's case. On that basis, an assessment for the search-related year must be made, if at all, under section 153C read with section 153A; framing it under section 143(3) is a fatal jurisdictional defect. The impugned assessment for Assessment Year 2017-18 was therefore treated as without jurisdiction.
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