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...
Finalisation of Provisional assessment - Two different block periods of four months and two months were taken only to satisfy the six month period as prescribed under sub-Rule (3) of Rule 7 for finalisation of the provisional assessment, which period commences from the date of supply of the details - there could be no clubbing of the various months falling within the period of provisional assessment, as permitted under Rule 7(1) - HC
Finalisation of Provisional assessment - Two different block periods of four months and two months were taken only to satisfy the six month period as prescribed under sub-Rule (3) of Rule 7 for finalisation of the provisional assessment, which period commences from the date of supply of the details - there could be no clubbing of the various months falling within the period of provisional assessment, as permitted under Rule 7(1) - HC
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