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...
Scope and applicability of Section 64(1)(iii) w.e.f. 1.4.1976 - from the date mention of that FY OR AY - liability can only be fastened on an individual if the same was existing at the time of accrual and not at the time of assessment and new liability under the IT Act cannot be given a retrospective effect - applicable in FY 1976-77 i.e AY 1977-78 not in AY 1976-77
Scope and applicability of Section 64(1)(iii) w.e.f. 1.4.1976 - from the date mention of that FY OR AY - liability can only be fastened on an individual if the same was existing at the time of accrual and not at the time of assessment and new liability under the IT Act cannot be given a retrospective effect - applicable in FY 1976-77 i.e AY 1977-78 not in AY 1976-77
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