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...
Exemption u/s 10A – t only the assessee knows whether it was expansion or a new undertaking and having led the department to accept that it is an expansion it cannot now be allowed to insist that it should now be treated as a fresh undertaking having been set up 7 or 10 years ago as this would be a travesty of justice. - AT
Exemption u/s 10A – t only the assessee knows whether it was expansion or a new undertaking and having led the department to accept that it is an expansion it cannot now be allowed to insist that it should now be treated as a fresh undertaking having been set up 7 or 10 years ago as this would be a travesty of justice. - AT
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