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...
Specialised qualifications for agricultural-land valuers are justified by the technical factors required in valuation, including land classification, crops, soil quality, fertility, irrigation, cultivation and comparable sales. Rule 8A(3) validly requires a degree in Agricultural Science and relevant farm-valuation experience, while treating specified former Government officers with prescribed service experience as a distinct eligible class based on their land-administration and valuation experience. The rule is not arbitrary or discriminatory merely because persons with other qualifications, including Civil Engineering, claim competence. The constitutional challenge under Articles 14 and 19 failed, and rejection of registration for lack of the prescribed qualification remained undisturbed.
Specialised qualifications for agricultural-land valuers are justified by the technical factors required in valuation, including land classification, crops, soil quality, fertility, irrigation, cultivation and comparable sales. Rule 8A(3) validly requires a degree in Agricultural Science and relevant farm-valuation experience, while treating specified former Government officers with prescribed service experience as a distinct eligible class based on their land-administration and valuation experience. The rule is not arbitrary or discriminatory merely because persons with other qualifications, including Civil Engineering, claim competence. The constitutional challenge under Articles 14 and 19 failed, and rejection of registration for lack of the prescribed qualification remained undisturbed.
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