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...
Direction to IT department to examine source of fund - petitioner made a complaint with the Income Tax Authorities - the assessment for the relevant period are already over as well as the stipulated period during which the assessments could be reopened has also expired - petition is highly belated and no direction can be granted
Direction to IT department to examine source of fund - petitioner made a complaint with the Income Tax Authorities - the assessment for the relevant period are already over as well as the stipulated period during which the assessments could be reopened has also expired - petition is highly belated and no direction can be granted
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