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...
Extended period of limitation - That an Explanation had to be inserted in 2010 in the charging provision of section 65 (105) makes it apparent that confusion about the scope of this tax existed in the minds of not just institutions but also tax officers - demand beyond normal period set aside - AT
Extended period of limitation - That an Explanation had to be inserted in 2010 in the charging provision of section 65 (105) makes it apparent that confusion about the scope of this tax existed in the minds of not just institutions but also tax officers - demand beyond normal period set aside - AT
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