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...
Contempt Petition - allegation is that the case of the petitioner for amendment of TRAN-1 form was not considered and no orders were passed in the case of petitioner - Department has processed the case and found that there was no logs of error evidencing any technical glitch faced by taxpayer - Since department has considered and processed the case, it cannot be said the respondents have flouted the judgment passed by this Court. - HC
Contempt Petition - allegation is that the case of the petitioner for amendment of TRAN-1 form was not considered and no orders were passed in the case of petitioner - Department has processed the case and found that there was no logs of error evidencing any technical glitch faced by taxpayer - Since department has considered and processed the case, it cannot be said the respondents have flouted the judgment passed by this Court. - HC
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