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...
Recovery of dues of the erstwhile owners of the property - attachment orders - The transfer took place in the year 2007. No action was taken by the department for nearly 10 years. It was only when the petitioner asked for benefit of amnesty scheme the said view was taken. Even on ground of delay, laches and inaction, the department cannot be allowed to open such old issues. - HC
Recovery of dues of the erstwhile owners of the property - attachment orders - The transfer took place in the year 2007. No action was taken by the department for nearly 10 years. It was only when the petitioner asked for benefit of amnesty scheme the said view was taken. Even on ground of delay, laches and inaction, the department cannot be allowed to open such old issues. - HC
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