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...
It was just and proper for the Revenue to demonstrate as to how the admissions made before the Settlement Commission were erroneous and it was just and proper for the CESTAT to record a finding as to why the admissions made by the Revenue before the Settlement Commission were not binding on the Revenue - HC
It was just and proper for the Revenue to demonstrate as to how the admissions made before the Settlement Commission were erroneous and it was just and proper for the CESTAT to record a finding as to why the admissions made by the Revenue before the Settlement Commission were not binding on the Revenue - HC
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