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...
Section 73(9) does not permit the Proper Officer to determine tax liability before the statutory due date for filing the annual return for the relevant financial year has expired. An assessment made before that deadline is premature and beyond the Proper Officer's authority. The premature assessment order was set aside, with fresh assessment proceedings to be undertaken in accordance with law after proper notice and an opportunity of hearing.
Section 73(9) does not permit the Proper Officer to determine tax liability before the statutory due date for filing the annual return for the relevant financial year has expired. An assessment made before that deadline is premature and beyond the Proper Officer's authority. The premature assessment order was set aside, with fresh assessment proceedings to be undertaken in accordance with law after proper notice and an opportunity of hearing.
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