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...
100% EOU - cement plant with units both in India and Bangladesh - doctrine of promissory estoppel - learned single Judge has rightly applied doctrine of promissory estoppel against the revenue, particularly when there was no misrepresentation made by the writ petitioner - HC
100% EOU - cement plant with units both in India and Bangladesh - doctrine of promissory estoppel - learned single Judge has rightly applied doctrine of promissory estoppel against the revenue, particularly when there was no misrepresentation made by the writ petitioner - HC
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