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...
Amendment of section 279 - It is proposed to amend the said sub-section so as to provide that the prosecution proceeding shall not be proceeded against a person for offences under section 276C or section 277 in respect of whom penalty under section 270A has also been reduced or waived under section 273A.
Amendment of section 279 - It is proposed to amend the said sub-section so as to provide that the prosecution proceeding shall not be proceeded against a person for offences under section 276C or section 277 in respect of whom penalty under section 270A has also been reduced or waived under section 273A.
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