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...
Assessee in default - proceedings u/s. 201(1) and 201(1A) - payment to non resident u/s 195 - limitation to pass order u/s. 201 shall be one year from the end of financial year in which proceedings u/s. 201 were initiated - Section 201(3) does not apply as it relates only to the payments made without TDS to person resident in India
Assessee in default - proceedings u/s. 201(1) and 201(1A) - payment to non resident u/s 195 - limitation to pass order u/s. 201 shall be one year from the end of financial year in which proceedings u/s. 201 were initiated - Section 201(3) does not apply as it relates only to the payments made without TDS to person resident in India
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