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...
An assessment made as a consequential order under the revision mechanism does not survive once the underlying revision orders are set aside and remitted for fresh consideration. Here, the Tribunal held that the assessment passed under sections 147, 263 and 144B depended entirely on section 263 orders that had already been sent back to the Principal Commissioner for a fresh order. Because that foundation had ceased to exist, the assessment order and the appellate order affirming it were treated as infructuous, and the appeals were dismissed on that basis.
An assessment made as a consequential order under the revision mechanism does not survive once the underlying revision orders are set aside and remitted for fresh consideration. Here, the Tribunal held that the assessment passed under sections 147, 263 and 144B depended entirely on section 263 orders that had already been sent back to the Principal Commissioner for a fresh order. Because that foundation had ceased to exist, the assessment order and the appellate order affirming it were treated as infructuous, and the appeals were dismissed on that basis.
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