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...
Reopening of assessment u/s 147 - the dropping of the earlier proceedings was only on account of technical reasons. It was not after a thorough scrutiny and consideration of the reply of the petitioner. It was withdrawn only for technical reason to pave way for issue of a fresh notice under Section 148 of the Income Tax Act, 1961 on 24.03.2017. The earlier proceedings initiated vide Notice dated 4.12.2015 was not dropped on merits. - Issuance of earlier notice under Section 148 of the Income Tax Act, 1961 did not preclude issue of fresh notice under the same section - HC
Reopening of assessment u/s 147 - the dropping of the earlier proceedings was only on account of technical reasons. It was not after a thorough scrutiny and consideration of the reply of the petitioner. It was withdrawn only for technical reason to pave way for issue of a fresh notice under Section 148 of the Income Tax Act, 1961 on 24.03.2017. The earlier proceedings initiated vide Notice dated 4.12.2015 was not dropped on merits. - Issuance of earlier notice under Section 148 of the Income Tax Act, 1961 did not preclude issue of fresh notice under the same section - HC
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