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...
Interest on delayed refunds arising from appellate-effect orders for Assessment Years 2014-15 to 2016-17 was directed to be computed under Section 244A(1A) from 1 December 2025 until payment, with additional Section 244A interest for September 2026 if payment was not made within the stipulated period. The Assessing Officer was required to secure consequential payment through the CPC. For Assessment Year 2014-15, the Assessing Officer was also required to verify the difference between tax deducted at source credit in the appellate-effect order and Form 26AS; if a short grant was established, interest under Section 244A(1) would run from 1 April 2014 until payment. No further direction applied to Assessment Year 2009-10.
Interest on delayed refunds arising from appellate-effect orders for Assessment Years 2014-15 to 2016-17 was directed to be computed under Section 244A(1A) from 1 December 2025 until payment, with additional Section 244A interest for September 2026 if payment was not made within the stipulated period. The Assessing Officer was required to secure consequential payment through the CPC. For Assessment Year 2014-15, the Assessing Officer was also required to verify the difference between tax deducted at source credit in the appellate-effect order and Form 26AS; if a short grant was established, interest under Section 244A(1) would run from 1 April 2014 until payment. No further direction applied to Assessment Year 2009-10.
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