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...
Jurisdiction in writ proceedings - challenge of order of assessment and Tax Recovery proceedings - The very question of validity or otherwise of service the notices of assessment would require detail examination of facts and validity does not rest only on legal contentions - availability of alternative efficacious remedy would be a ground to refuse to entertain the writ petition
Jurisdiction in writ proceedings - challenge of order of assessment and Tax Recovery proceedings - The very question of validity or otherwise of service the notices of assessment would require detail examination of facts and validity does not rest only on legal contentions - availability of alternative efficacious remedy would be a ground to refuse to entertain the writ petition
Note: It is a system-generated summary and is for quick reference only.