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...
Levy of penalty - The proprietor of the firm had given a Letter of Authority to the Manager to look after the day-to-day affairs. Therefore the penalties imposed on the proprietor seems to be unwarranted as he may have been kept in dark by the Manager and the same is liable to be set aside. - AT
Levy of penalty - The proprietor of the firm had given a Letter of Authority to the Manager to look after the day-to-day affairs. Therefore the penalties imposed on the proprietor seems to be unwarranted as he may have been kept in dark by the Manager and the same is liable to be set aside. - AT
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