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 - bogus transactions or accommodation entries involving the assessee - the petitioner was issued a notice under section 133(6) of the said Act requesting it to furnish the evidence to prove the genuineness of the transactions mentioned therein before the issuance of the impugned notice u/s 148 of the said Act, however, the petitioner had chosen not to respond to the said notice. - Reopening sustained - HC
Reopening of assessment u/s 147 - bogus transactions or accommodation entries involving the assessee - the petitioner was issued a notice under section 133(6) of the said Act requesting it to furnish the evidence to prove the genuineness of the transactions mentioned therein before the issuance of the impugned notice u/s 148 of the said Act, however, the petitioner had chosen not to respond to the said notice. - Reopening sustained - HC
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