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...
Statutory pre-deposit and delay condonation framed the operative relief: the writ petition was disposed of by granting liberty to file the challenge to the impugned order within two weeks, along with the statutory pre-deposit and an application for condonation of delay. All grounds were left open, and the appellate authority was directed to examine the delay question first and, if satisfied, decide the matter on merits in accordance with law.
Statutory pre-deposit and delay condonation framed the operative relief: the writ petition was disposed of by granting liberty to file the challenge to the impugned order within two weeks, along with the statutory pre-deposit and an application for condonation of delay. All grounds were left open, and the appellate authority was directed to examine the delay question first and, if satisfied, decide the matter on merits in accordance with law.
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