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...
In the original return of income, since the assessee has not made the claim, the assessee could not have filed the Form No. 3CEA along with the return of income. Its only during the reassessment proceedings, that the assessee had made an alternate claim and therefore, the CIT(A) has rightly directed the A.O to assess the transaction arising out of the BPA as a slump sale u/s 50B of the IT Act. - AT
In the original return of income, since the assessee has not made the claim, the assessee could not have filed the Form No. 3CEA along with the return of income. Its only during the reassessment proceedings, that the assessee had made an alternate claim and therefore, the CIT(A) has rightly directed the A.O to assess the transaction arising out of the BPA as a slump sale u/s 50B of the IT Act. - AT
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