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...
Disallowance of ITC - perversity - alternative appeal remedy - even the exercise were for the limited purpose of finding out the ground of perversity, this Court may encroach into the function of an appellate authority where the facts threadbare are considered, thereafter principle of law decided - petitioner is given liberty to file appeal.
Disallowance of ITC - perversity - alternative appeal remedy - even the exercise were for the limited purpose of finding out the ground of perversity, this Court may encroach into the function of an appellate authority where the facts threadbare are considered, thereafter principle of law decided - petitioner is given liberty to file appeal.
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