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...
Reopening of assessment u/s 147 - Jurisdiction - objections were raised by the assessee u/s 124(3) of the Act, within one month of receipt of notice u/s 148 of the Act and the Assessing Officer who issued notice u/s 148 of the Act, accepted that he had no jurisdiction on this case and thus transferred the case to the ITO, Ward-4(3), who had jurisdiction. A notice issued by non-jurisdictional Assessing Officer is illegal.
Reopening of assessment u/s 147 - Jurisdiction - objections were raised by the assessee u/s 124(3) of the Act, within one month of receipt of notice u/s 148 of the Act and the Assessing Officer who issued notice u/s 148 of the Act, accepted that he had no jurisdiction on this case and thus transferred the case to the ITO, Ward-4(3), who had jurisdiction. A notice issued by non-jurisdictional Assessing Officer is illegal.
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