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 extended period beyond six assessment years for a search assessment under the fourth proviso to section 153A(1) applies only where material available to the Assessing Officer shows escaped income represented by a stipulated asset of the required value. Alleged on-money receipts from project buyers, without a finding that those receipts were represented by such an asset, do not meet that condition. Assessments initiated beyond the six-year period on that basis were void ab initio, and the consequential reassessment orders for the relevant years were invalid.
The extended period beyond six assessment years for a search assessment under the fourth proviso to section 153A(1) applies only where material available to the Assessing Officer shows escaped income represented by a stipulated asset of the required value. Alleged on-money receipts from project buyers, without a finding that those receipts were represented by such an asset, do not meet that condition. Assessments initiated beyond the six-year period on that basis were void ab initio, and the consequential reassessment orders for the relevant years were invalid.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
