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...
Attachment of the immovable properties and bank accounts of the Petitioner - expiry of a period of one year from the date of the order made under Section 83(1) - After the issuance of the impugned orders, no fresh attachment order has been issued. Consequently, this Court directs the Respondent to defreeze the bank account and release the immovable properties of the Petitioner not later than three days from the date of uploading the order. - HC
Attachment of the immovable properties and bank accounts of the Petitioner - expiry of a period of one year from the date of the order made under Section 83(1) - After the issuance of the impugned orders, no fresh attachment order has been issued. Consequently, this Court directs the Respondent to defreeze the bank account and release the immovable properties of the Petitioner not later than three days from the date of uploading the order. - HC
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