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...
Revisional power over an assessment requires the order to be both erroneous and prejudicial to the Revenue; it cannot be used to replace a legally plausible view already taken after inquiry. Here, the Assessing Officer examined alleged bogus purchases and made an addition of 12.5%, so the dispute was only over the quantum and manner of addition, not a lack of inquiry. As no illegality was shown in the assessment view, revision under Section 263 was not available, and the Tribunal's setting aside of the revisional order was upheld.
Revisional power over an assessment requires the order to be both erroneous and prejudicial to the Revenue; it cannot be used to replace a legally plausible view already taken after inquiry. Here, the Assessing Officer examined alleged bogus purchases and made an addition of 12.5%, so the dispute was only over the quantum and manner of addition, not a lack of inquiry. As no illegality was shown in the assessment view, revision under Section 263 was not available, and the Tribunal's setting aside of the revisional order was upheld.
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