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...
Revision u/s 263 - loss on sale of shares - non-mentioning of the reasons for allowing the claim, will not make the assessment order erroneous. To hold the assessment order to be erroneous it has to be stablished that the AO had not applied his mind to the facts of the case or that he has not applied the correct law or has not appreciated the facts correctly. Thus, the assessment order cannot be held to be prejudicial to the interests of the revenue on this issue. - AT
Revision u/s 263 - loss on sale of shares - non-mentioning of the reasons for allowing the claim, will not make the assessment order erroneous. To hold the assessment order to be erroneous it has to be stablished that the AO had not applied his mind to the facts of the case or that he has not applied the correct law or has not appreciated the facts correctly. Thus, the assessment order cannot be held to be prejudicial to the interests of the revenue on this issue. - AT
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