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 of AO - transfer of case u/s 127 - AO at Kurnool had transferred the file to the AO at Hyderabad - only the Pr. Director General or the Pr. CIT or Pr. CIT can transfer the case u/s 127 - issuance u/s 143(2) by the Dy. CIT (IT)-1, Hyderabad is without any authority and also beyond the period of six months from the date of filing of returns
Jurisdiction of AO - transfer of case u/s 127 - AO at Kurnool had transferred the file to the AO at Hyderabad - only the Pr. Director General or the Pr. CIT or Pr. CIT can transfer the case u/s 127 - issuance u/s 143(2) by the Dy. CIT (IT)-1, Hyderabad is without any authority and also beyond the period of six months from the date of filing of returns
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