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...
Payment of interest to the petitioner - especially when the respondent-State had retained such a substantial amount belonging to the petitioner with it for more than 8 years, in our opinion, it would be just and appropriate to compensate the petitioner - SC
Payment of interest to the petitioner - especially when the respondent-State had retained such a substantial amount belonging to the petitioner with it for more than 8 years, in our opinion, it would be just and appropriate to compensate the petitioner - SC
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