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...
The doctrine of merger applies where the Appellate Tribunal has passed a final order in an appeal: prior interlocutory orders, including a recall order, merge into the final appellate order and cease to have independent existence. A writ petition challenging the recall order therefore cannot survive once the final order is challenged through the available statutory tax appeal. The challenge to the final order must be pursued in that statutory appellate remedy, and the writ petition was dismissed.
The doctrine of merger applies where the Appellate Tribunal has passed a final order in an appeal: prior interlocutory orders, including a recall order, merge into the final appellate order and cease to have independent existence. A writ petition challenging the recall order therefore cannot survive once the final order is challenged through the available statutory tax appeal. The challenge to the final order must be pursued in that statutory appellate remedy, and the writ petition was dismissed.
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