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...
Extraordinary delay in filing revisions was not condoned because the explanation of wrong legal advice and bona fide misconception was contrary to the record and did not satisfy "sufficient cause"; the revisions against conviction were dismissed as time-barred. The settlement agreement did not extinguish the pending Section 138 complaints because withdrawal was expressly conditional on full payment, and default kept the complainant's right to proceed alive; quashing was refused. Civil execution and criminal cheque-dishonour proceedings were held to operate in distinct fields, so double jeopardy did not apply and probation was declined. Earlier and later payments were credited while computing liability, leading only to a limited reduction in fine.
Extraordinary delay in filing revisions was not condoned because the explanation of wrong legal advice and bona fide misconception was contrary to the record and did not satisfy "sufficient cause"; the revisions against conviction were dismissed as time-barred. The settlement agreement did not extinguish the pending Section 138 complaints because withdrawal was expressly conditional on full payment, and default kept the complainant's right to proceed alive; quashing was refused. Civil execution and criminal cheque-dishonour proceedings were held to operate in distinct fields, so double jeopardy did not apply and probation was declined. Earlier and later payments were credited while computing liability, leading only to a limited reduction in fine.
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