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 transaction entered into by the applicant with the company in liquidation - It cannot be said that the applicant has entered into transaction of purchase of sale of the assets of the company without good faith or bona fide intention, more particularly, when the applicant has deposited the entire sale consideration with DENA bank with whom the property which was purchased by the applicant was mortgaged - HC
Validity of transaction entered into by the applicant with the company in liquidation - It cannot be said that the applicant has entered into transaction of purchase of sale of the assets of the company without good faith or bona fide intention, more particularly, when the applicant has deposited the entire sale consideration with DENA bank with whom the property which was purchased by the applicant was mortgaged - HC
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