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...
Revision u/s 263 - There cannot be any estoppel against law and method of accounting/policy followed by tax-payer which is contrary to law even if accepted by the AO after due enquiry cannot be said to be a view which could be said to be one of the possible or a plausible view - view of the Ld. CIT cannot be held to be merely a change of opinion - revision upheld
Revision u/s 263 - There cannot be any estoppel against law and method of accounting/policy followed by tax-payer which is contrary to law even if accepted by the AO after due enquiry cannot be said to be a view which could be said to be one of the possible or a plausible view - view of the Ld. CIT cannot be held to be merely a change of opinion - revision upheld
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