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...
Inclusion of AY in which search was conducted into the period of 6 assessment years - recording of satisfaction during the next year - assessment for assessment year 2008-09 should have been completed u/s 153A read with 153C and not as regular assessment u/s 143(3), by treating the A.Y. 2008-09 as year of search. - AT
Inclusion of AY in which search was conducted into the period of 6 assessment years - recording of satisfaction during the next year - assessment for assessment year 2008-09 should have been completed u/s 153A read with 153C and not as regular assessment u/s 143(3), by treating the A.Y. 2008-09 as year of search. - AT
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