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...
Cancellation of redemption certificate - validity of SCN - power of review - The contentions raised that the redemption certificate is final order, which can be reviewed under Section 16 of the Act is untenable and the redemption certificates issued based on the informations furnished by the petitioner, can never be construed as an order issued after adjudication for the purpose of exercise of power of review and therefore, the impugned show cause notice is issued, based on the report submitted by the Director of Revenue Intelligence, which is a fresh cause of action and more so, in respect of the documents furnished by the petitioner for the purpose of getting a redemption certificate and thus, such illegality or irregularity if any noticed, is to be proceeded with by following the procedures as contemplated under law. - HC
Cancellation of redemption certificate - validity of SCN - power of review - The contentions raised that the redemption certificate is final order, which can be reviewed under Section 16 of the Act is untenable and the redemption certificates issued based on the informations furnished by the petitioner, can never be construed as an order issued after adjudication for the purpose of exercise of power of review and therefore, the impugned show cause notice is issued, based on the report submitted by the Director of Revenue Intelligence, which is a fresh cause of action and more so, in respect of the documents furnished by the petitioner for the purpose of getting a redemption certificate and thus, such illegality or irregularity if any noticed, is to be proceeded with by following the procedures as contemplated under law. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
