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...
Condonation of delay - to seek that the period of limitation provided in the statute be ignored in case of Revenue's appeals cannot be accepted. The Appeals which are filed by the Revenue in this Court under Section 260A of the Act are very large in number and on an average over 2000 per year from the orders of the Tribunal. Thus, the officers of the Revenue should be well aware of the statutory provisions and the period of limitation and should pursue its remedies diligently. - HC
Condonation of delay - to seek that the period of limitation provided in the statute be ignored in case of Revenue's appeals cannot be accepted. The Appeals which are filed by the Revenue in this Court under Section 260A of the Act are very large in number and on an average over 2000 per year from the orders of the Tribunal. Thus, the officers of the Revenue should be well aware of the statutory provisions and the period of limitation and should pursue its remedies diligently. - HC
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