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of an Ordinance which levied an additional sales tax @ not exceeding to 3% of the gross turnover - Ordinance was withdrawn in 1995 - The Court is unable to agree with the view expressed by the Tribunal that notwithstanding the clarification of the Government, the Ordinance in question was still required to be enforced for the period of its operation - the impugned order of the Tribunal and the corresponding orders of the ACST and STO seeking to enforce the Ordinance are hereby set aside - HC
Validity of an Ordinance which levied an additional sales tax @ not exceeding to 3% of the gross turnover - Ordinance was withdrawn in 1995 - The Court is unable to agree with the view expressed by the Tribunal that notwithstanding the clarification of the Government, the Ordinance in question was still required to be enforced for the period of its operation - the impugned order of the Tribunal and the corresponding orders of the ACST and STO seeking to enforce the Ordinance are hereby set aside - HC
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