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...
Levy of Entry Tax - it is evident that an exemption Notification should be strictly interpreted and the burden of proving its applicability is on the assessee to show how his comes within purview of exemption Notification. - The revisional authority is required to record the findings on the factual aspect viz., whether goods viz., drill bits, millers and inserts have been consumed as inputs in the process of manufacture of finished goods viz., textile machinery and auto parts. However, no finding has been recorded by the revisional authority. - Matter remanded back - HC
Levy of Entry Tax - it is evident that an exemption Notification should be strictly interpreted and the burden of proving its applicability is on the assessee to show how his comes within purview of exemption Notification. - The revisional authority is required to record the findings on the factual aspect viz., whether goods viz., drill bits, millers and inserts have been consumed as inputs in the process of manufacture of finished goods viz., textile machinery and auto parts. However, no finding has been recorded by the revisional authority. - Matter remanded back - HC
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