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...
Redemption fine imposed in lieu of confiscation cannot be included in the estimated amount payable under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. High Court treated the issue as covered by an earlier High Court ruling and noted that the related special leave petition had been dismissed. The inclusion of redemption fine was quashed, and the authorities were directed to recalculate the Scheme liability after excluding it. A discharge certificate must issue once the legally recoverable dues are paid and all Scheme conditions are met.
Redemption fine imposed in lieu of confiscation cannot be included in the estimated amount payable under the Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019. High Court treated the issue as covered by an earlier High Court ruling and noted that the related special leave petition had been dismissed. The inclusion of redemption fine was quashed, and the authorities were directed to recalculate the Scheme liability after excluding it. A discharge certificate must issue once the legally recoverable dues are paid and all Scheme conditions are met.
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