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...
Objections to reassessment must address material submissions relevant to the alleged source of funds for share purchases. Although the Assessing Officer's reasoning appeared prima facie sustainable on the material initially available, later material comprising a letter and annexures concerning loans and own funds also required consideration before the objections were decided. The order rejecting the objections was therefore set aside, with directions for fresh consideration after examining the additional material. The validity of the reopening was not decided, and all contentions on its merits remained open.
Objections to reassessment must address material submissions relevant to the alleged source of funds for share purchases. Although the Assessing Officer's reasoning appeared prima facie sustainable on the material initially available, later material comprising a letter and annexures concerning loans and own funds also required consideration before the objections were decided. The order rejecting the objections was therefore set aside, with directions for fresh consideration after examining the additional material. The validity of the reopening was not decided, and all contentions on its merits remained open.
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