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...
Unexplained investment in land - the appellant had entered into a deal to purchase this land and subsequent gone to get it registered; the eventual seller to her had registered it earlier as a purchaser; she was purported to be clearly 50% owner; no one can believe that she was entitled to such a benefit without spending a single rupee. - AT
Unexplained investment in land - the appellant had entered into a deal to purchase this land and subsequent gone to get it registered; the eventual seller to her had registered it earlier as a purchaser; she was purported to be clearly 50% owner; no one can believe that she was entitled to such a benefit without spending a single rupee. - AT
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