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...
Third-party search assessments under section 153C require the seized material to be handed over to the other person's Assessing Officer before the statutory cut-off. Where handover occurs after 1 April 2021, section 153C is unavailable and proceedings may be pursued only under reassessment provisions; the resulting notice and assessment lack jurisdiction. Penalty for cash acceptance contrary to section 269SS, when unrelated to assessment, is subject to the limitation period beginning with the Assessing Officer's recommendation to initiate penalty proceedings. A penalty order issued after that period is time-barred and liable to be quashed.
Third-party search assessments under section 153C require the seized material to be handed over to the other person's Assessing Officer before the statutory cut-off. Where handover occurs after 1 April 2021, section 153C is unavailable and proceedings may be pursued only under reassessment provisions; the resulting notice and assessment lack jurisdiction. Penalty for cash acceptance contrary to section 269SS, when unrelated to assessment, is subject to the limitation period beginning with the Assessing Officer's recommendation to initiate penalty proceedings. A penalty order issued after that period is time-barred and liable to be quashed.
Note: It is a system-generated summary and is for quick reference only.
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