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...
Whether the re-assessment proceedings initiated against the petitioner are barred by limitation? - The amendment made to Section 40 of the Act, cannot be construed so as to open up a liability which had become barred. Even by retrospective operation of law, the aforesaid vested right accrued to the petitioner cannot be taken away - the re-assessment proceedings for the period between April 2006 to December 2006 and April 2007 to December 2007 is held to be barred by limitation. - HC
Whether the re-assessment proceedings initiated against the petitioner are barred by limitation? - The amendment made to Section 40 of the Act, cannot be construed so as to open up a liability which had become barred. Even by retrospective operation of law, the aforesaid vested right accrued to the petitioner cannot be taken away - the re-assessment proceedings for the period between April 2006 to December 2006 and April 2007 to December 2007 is held to be barred by limitation. - HC
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