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...
Compounding of offences and payment of compounding fee - there are no complaints and there is no inspection/investigation pending. - In the present case, the company has made an application suo motu and has stated that this or similar offences has not been compounded during the last three years - it is considered reasonable to compound the offence under Section 67(3) of the Companies Act, 1956 - Tri
Compounding of offences and payment of compounding fee - there are no complaints and there is no inspection/investigation pending. - In the present case, the company has made an application suo motu and has stated that this or similar offences has not been compounded during the last three years - it is considered reasonable to compound the offence under Section 67(3) of the Companies Act, 1956 - Tri
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