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...
Interest levied by Revenue u/s 234A and 234B - adjustment of cash seized with the tax-liability determined on assessment - the assessee cannot blame Revenue for its own faults in not keeping proper and true record of its own income. The onus and burden is on the assessee to file its return of income in time, which the assessee cannot shift to Revenue merely because an intervening event by way of search and seizure operations have taken place u/s 132(1) of the 1961 Act. - Relief granted for interest u/s 234B but not u/s 234A - AT
Interest levied by Revenue u/s 234A and 234B - adjustment of cash seized with the tax-liability determined on assessment - the assessee cannot blame Revenue for its own faults in not keeping proper and true record of its own income. The onus and burden is on the assessee to file its return of income in time, which the assessee cannot shift to Revenue merely because an intervening event by way of search and seizure operations have taken place u/s 132(1) of the 1961 Act. - Relief granted for interest u/s 234B but not u/s 234A - AT
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