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...
SCMTR, 2018 is to be implemented pan-India with all message developments, except Import Transhipment messages, becoming fully operational from 01.07.2026. Transitional provisions are extended up to 31.08.2026 to enable stakeholders to file prescribed electronic messages, other than ITP, and field formations are directed to support implementation through advisories, outreach and resolution of system issues. No penal action is to be initiated for technical or procedural difficulties faced in the online filing mechanism under SCMTR, 2018 up to 31.08.2026.
SCMTR, 2018 is to be implemented pan-India with all message developments, except Import Transhipment messages, becoming fully operational from 01.07.2026. Transitional provisions are extended up to 31.08.2026 to enable stakeholders to file prescribed electronic messages, other than ITP, and field formations are directed to support implementation through advisories, outreach and resolution of system issues. No penal action is to be initiated for technical or procedural difficulties faced in the online filing mechanism under SCMTR, 2018 up to 31.08.2026.
Note: It is a system-generated summary and is for quick reference only.