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...
Treatment as a resident in India - Passport being unjustifiably impounded - it was impossible for the assessee to leave India - He virtually became an unwilling resident on Indian soil without his consent and against his will - such period must be excluded - Cannot be treated as Resident - HC
Treatment as a resident in India - Passport being unjustifiably impounded - it was impossible for the assessee to leave India - He virtually became an unwilling resident on Indian soil without his consent and against his will - such period must be excluded - Cannot be treated as Resident - HC
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