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...
Validity of assessment - show cause notice has been issued manually - The petitioner refers to a snap shot of the E-portal contending that does not refer to show cause notice dated 20.05.2019. This would, at best, amount to a technical error and will not vitiate the assessment itself for the reason that the show cause notice has been manually issued and proof of service of the same is also available on record. - The challenge to the assessment thus fails - HC
Validity of assessment - show cause notice has been issued manually - The petitioner refers to a snap shot of the E-portal contending that does not refer to show cause notice dated 20.05.2019. This would, at best, amount to a technical error and will not vitiate the assessment itself for the reason that the show cause notice has been manually issued and proof of service of the same is also available on record. - The challenge to the assessment thus fails - HC
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