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...
Extended period of limitation - Except mentioning in the show cause notice that there has been suppression of facts, no positive act committed by the appellant has been put forth by the revenue to allege suppression of facts in the impugned cases. The detection is subsequent to the audit - SCN was not required to be issued.
Extended period of limitation - Except mentioning in the show cause notice that there has been suppression of facts, no positive act committed by the appellant has been put forth by the revenue to allege suppression of facts in the impugned cases. The detection is subsequent to the audit - SCN was not required to be issued.
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