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...
Service and issuance of notice u/s 143(2) - scope of insertion of Section 292BB - for Section 292BB to apply, the notice must have emanated from the department, it is only the infirmities in the manner of service of notice that the Section seeks to cure - The Section is not intended to cure complete absence of notice itself - issuance of notice u/s 143(2) is mandatory
Service and issuance of notice u/s 143(2) - scope of insertion of Section 292BB - for Section 292BB to apply, the notice must have emanated from the department, it is only the infirmities in the manner of service of notice that the Section seeks to cure - The Section is not intended to cure complete absence of notice itself - issuance of notice u/s 143(2) is mandatory
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