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 Employees’ Contribution to PF - inadvertently disallowed in the revised return despite remitted within the due dates - DRP brushed aside the assessee’s claim holding that in view of section 144C(1) the claim does not relate to any variation made by the AO - whatever may be the fetters placed on the scope of the powers of the DRP, there can be no estoppel against the application/operation of law laid by the Hon’ble jurisdictional High Court - allowable
Disallowance of Employees’ Contribution to PF - inadvertently disallowed in the revised return despite remitted within the due dates - DRP brushed aside the assessee’s claim holding that in view of section 144C(1) the claim does not relate to any variation made by the AO - whatever may be the fetters placed on the scope of the powers of the DRP, there can be no estoppel against the application/operation of law laid by the Hon’ble jurisdictional High Court - allowable
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