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...
Reopening of assessment u/s 147 - wrong facts in reasons recorded - AO completely ignored the fact that the return was already filed on 18.01.2010 and vide letter dated 24.02.2012 the assessee has explained that he is a regular assessee and produced the copy of Income-tax return filed - assumption of jurisdiction by the AO is bad in law
Reopening of assessment u/s 147 - wrong facts in reasons recorded - AO completely ignored the fact that the return was already filed on 18.01.2010 and vide letter dated 24.02.2012 the assessee has explained that he is a regular assessee and produced the copy of Income-tax return filed - assumption of jurisdiction by the AO is bad in law
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
