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...
Revised monetary-limit exceptions in departmental appeals operate prospectively, so appeals filed before the modifying CBDT communication remain governed by the earlier limits. Where the tax effect is below the prescribed threshold, the appeal is not maintainable and is disposed of on that ground without examination of the merits. The substantial questions of law are left open, and the newly introduced exceptions cannot be applied retrospectively to pending appeals instituted earlier.
Revised monetary-limit exceptions in departmental appeals operate prospectively, so appeals filed before the modifying CBDT communication remain governed by the earlier limits. Where the tax effect is below the prescribed threshold, the appeal is not maintainable and is disposed of on that ground without examination of the merits. The substantial questions of law are left open, and the newly introduced exceptions cannot be applied retrospectively to pending appeals instituted earlier.
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