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...
Tribunal dismissing the Appeal instead of disposing the matter on merits - It appears that on account of inadvertence, the senior chartered accountant engaged by the assessee could not comply with the directions of the Tribunal to file the documents. The tribunal, infact, should have adjudicated the matter on merits instead of summarily dismissing the same. - HC
Tribunal dismissing the Appeal instead of disposing the matter on merits - It appears that on account of inadvertence, the senior chartered accountant engaged by the assessee could not comply with the directions of the Tribunal to file the documents. The tribunal, infact, should have adjudicated the matter on merits instead of summarily dismissing the same. - HC
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