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...
Valuation - Scope of the show cause notice (SCN) - Since the show cause notice or the appeal filed by Revenue does not propose to determine the assessable value of wholesale pack in the form in which it is offered for clearance, there are no merits in the appeal filed by the Revenue - AT
Valuation - Scope of the show cause notice (SCN) - Since the show cause notice or the appeal filed by Revenue does not propose to determine the assessable value of wholesale pack in the form in which it is offered for clearance, there are no merits in the appeal filed by the Revenue - AT
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