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...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
TP adjustment - scope of TP adjustment when assessee is eligible for exemption u/s 10B - Irrespective of profit making ability and exemption available in the country of operation the transfer price of the global market and the corporates must be within the band of pricing - tax saving alone cannot be a decision making process to restrict any TP adjustment
TP adjustment - scope of TP adjustment when assessee is eligible for exemption u/s 10B - Irrespective of profit making ability and exemption available in the country of operation the transfer price of the global market and the corporates must be within the band of pricing - tax saving alone cannot be a decision making process to restrict any TP adjustment
Note: It is a system-generated summary and is for quick reference only.
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