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...
Genuineness of purchases - non compliance of notices u/s 133(6) - non of entities declared as Hawala/Bogus dealers by any of the authorities - assessee was able to produce overwhelming documents to substantiate the purchase - same can not be disallowed only on ground that notices u/s 133(6) were not responded to, which was also not within the control of the assessee - purchases allowed
Genuineness of purchases - non compliance of notices u/s 133(6) - non of entities declared as Hawala/Bogus dealers by any of the authorities - assessee was able to produce overwhelming documents to substantiate the purchase - same can not be disallowed only on ground that notices u/s 133(6) were not responded to, which was also not within the control of the assessee - purchases allowed
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