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...
Cancellation/withdrawal of registration/approval u/s 12AA/10(23C)(vi) with retrospective effect - The AO while completing the assessment for AY 2010-11 after search found large scale diversion of funds and several improper actions in direct conflict to the terms of the Deed of Trust and conditions of registration/exemption and recommended to the competent authority to initiate proceedings for cancellation - it will take effect from the AY 2010-2011 and it is a mis-nomer that the orders are retrospective or retroactive
Cancellation/withdrawal of registration/approval u/s 12AA/10(23C)(vi) with retrospective effect - The AO while completing the assessment for AY 2010-11 after search found large scale diversion of funds and several improper actions in direct conflict to the terms of the Deed of Trust and conditions of registration/exemption and recommended to the competent authority to initiate proceedings for cancellation - it will take effect from the AY 2010-2011 and it is a mis-nomer that the orders are retrospective or retroactive
Note: It is a system-generated summary and is for quick reference only.