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...
Assessment order in the name of a dead person - there is an obligation on the LR to bring such fact to the notice of the AO - this fact was brought to the notice of the CIT (A) for the first time, he should have taken the said fact on record, which he has done, but he should either have passed the Assessment Orders on merits while exercising his appellate powers or remanded the same - ITAT correctly remanded to AO
Assessment order in the name of a dead person - there is an obligation on the LR to bring such fact to the notice of the AO - this fact was brought to the notice of the CIT (A) for the first time, he should have taken the said fact on record, which he has done, but he should either have passed the Assessment Orders on merits while exercising his appellate powers or remanded the same - ITAT correctly remanded to AO
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