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...
Validity of notice u/s 148 - AO has issued notice on 28.03.2014 though he has applied for approval which was granted on 29.03.2014 - very foundation for issuance of notice u/s 148 is the approval from the competent authority - in the absence of approval, such notice is void ab initio
Validity of notice u/s 148 - AO has issued notice on 28.03.2014 though he has applied for approval which was granted on 29.03.2014 - very foundation for issuance of notice u/s 148 is the approval from the competent authority - in the absence of approval, such notice is void ab initio
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