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 appeal was treated as timely where the appellant showed it had not earlier received the order-in-original, had repeatedly sought a copy through the department, the High Court and RTI, and filed the appeal within one month of actual receipt; the dismissal as time-barred was set aside. On limitation for the service tax demand, the Tribunal held that a notice issued solely on Form 26AS data, without enquiry into the nature of services or corroborative verification, could not sustain the demand or justify the extended period, especially after prolonged departmental inactivity; the confirmed demand was therefore set aside as barred by limitation.
An appeal was treated as timely where the appellant showed it had not earlier received the order-in-original, had repeatedly sought a copy through the department, the High Court and RTI, and filed the appeal within one month of actual receipt; the dismissal as time-barred was set aside. On limitation for the service tax demand, the Tribunal held that a notice issued solely on Form 26AS data, without enquiry into the nature of services or corroborative verification, could not sustain the demand or justify the extended period, especially after prolonged departmental inactivity; the confirmed demand was therefore set aside as barred by limitation.
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