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...
Valuation - cash discount = it is always open to the AO to take into consideration those documents and take a decision in the matter. - AO need not restrict himself only with regard to the C-Forms and F-Forms and if the assessee is legally entitled for any other relief then that may be considered - HC
Valuation - cash discount = it is always open to the AO to take into consideration those documents and take a decision in the matter. - AO need not restrict himself only with regard to the C-Forms and F-Forms and if the assessee is legally entitled for any other relief then that may be considered - HC
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