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...
Rectification of mistake - ITAT has allows appeal on merit & dismissed the assessee’s cross objections as infructuous regarding re-opening of assessment. Assesse not challenged that order. After reversal of appeal by High court on merit assesse filed rectification application before Tribunal. High Court held that rectification application filed by the assessee was barred by the principle of finality, and to an extent the doctrine of merger. High Court further held that this is not apparent mistake or error warranting rectification.
Rectification of mistake - ITAT has allows appeal on merit & dismissed the assessee’s cross objections as infructuous regarding re-opening of assessment. Assesse not challenged that order. After reversal of appeal by High court on merit assesse filed rectification application before Tribunal. High Court held that rectification application filed by the assessee was barred by the principle of finality, and to an extent the doctrine of merger. High Court further held that this is not apparent mistake or error warranting rectification.
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