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...
A writ challenge to reassessment notices on the ground that the Jurisdictional Assessing Officer lacked authority under the reassessment regime between 01.04.2021 and 01.04.2024 failed, because the retrospective insertion of Section 147A altered the foundation of contrary decisions and the jurisdictional objection no longer survived. The constitutional challenge to the amended provision was not examined in the Single Judge writ proceedings, as such a vires attack had to be pursued before the Division Bench under the High Court Writ Rules. Recovery was kept in abeyance for 30 days to permit the petitioners to seek appropriate relief before the Division Bench.
A writ challenge to reassessment notices on the ground that the Jurisdictional Assessing Officer lacked authority under the reassessment regime between 01.04.2021 and 01.04.2024 failed, because the retrospective insertion of Section 147A altered the foundation of contrary decisions and the jurisdictional objection no longer survived. The constitutional challenge to the amended provision was not examined in the Single Judge writ proceedings, as such a vires attack had to be pursued before the Division Bench under the High Court Writ Rules. Recovery was kept in abeyance for 30 days to permit the petitioners to seek appropriate relief before the Division Bench.
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